The Department of Health and Human Services (HHS) recently announced the 2026 Benefit Parameters, outlining the maximum out-of-pocket (OOP) limits applicable to non-grandfathered plans for plan years beginning in 2026. Each year, these OOP maximums are adjusted for inflation. In 2023, HHS pledged to release the updated amounts “by January of the year preceding the applicable benefit year” and they have indeed stuck to that promise.
Under the Affordable Care Act (ACA), non-grandfathered health plans are required to comply with an overall annual limit on out-of-pocket expenses for essential health benefits, regardless of whether the plan is self-funded or fully insured. The current limits applicable to 2025 plan years are $9,200 for self-only coverage and $18,400 for family coverage. The 2026 limits will be increased to $10,150 for self-only coverage and $20,300 for family coverage, respectively.
Here's a summary of the amounts for traditional plans for the 2025 / 2026 plan years for reference:
|
Traditional Plans |
HDHP / HSA Plans |
||
|
Single |
Family |
Single |
Family |
2026 |
$10,150 |
$20,300 |
TBD |
TBD |
2025 |
$9,200 |
$18,400 |
$8,300 |
$16,600 |
High-deductible health plans (HDHPs) with Health Savings Accounts (HSAs) feature different limits than traditional plans, including OOP maxes, along with deductible and contribution limits. Historically these limits are released in May of each year. For reference, the 2025 HDHP/HSA limits were not released by the IRS until May 9, 2024.
Although, it should be noted that if your plans offer both traditional and HDHP/HSA plans (that are not grandfathered), your plans are subject to both sets of requirements and you must ensure compliance with the lowest applicable out-of-pocket maximum. Plus, the ACA requires that a per person (individualized/embedded) out-of-pocket maximum doesn't exceed the ACA limit, even if you are in the larger (family) tier. This assists single family members in accessing benefits sooner without having to hit the full amount for the family tier.
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