The U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) have issued a final regulation to address the integrity of the Affordable Care Act (ACA) public exchanges and health coverage affordability. The final rule makes changes to annual cost-sharing limits, eligibility and enrollment procedures, and the definition of essential health benefits. A fact sheet is also available.
Of particular interest to group health plan sponsors is the change to the methodology for calculating the “premium adjustment percentage” used for setting certain limits under the ACA. As a result, the previously announced 2026 ACA maximum annual limitation on cost sharing that a group health plan can impose for 2026 is now $10,600 for individual coverage and $21,200 for family coverage (up from the previous $10,150 and $20,300, respectively).
Note: These limits are different from the IRS limits on health savings account-qualified high-deductible health plans.[1]
Many plan sponsors, particularly those with calendar-year plans, are currently working on finalizing plan designs for the 2026 plan year. These employers wishing to impose the higher cost-sharing limit will need to make sure their group health plans are using the revised annual cost-sharing limit, including in any 2026 plan materials and participant communications.
