New ACA Cost-Sharing Limits and Upcoming HHS Updates for 2026

HHS Outlines 2027 ACA Cost-Sharing Limits

The Department of Health and Human Services (HHS) has announced new cost-sharing limits for the 2027 benefit year for non-grandfathered group health plans under the Affordable Care Act (ACA). The maximum annual cost-sharing for self-only coverage will increase to $12,000, while other coverage limits will rise to $24,000. These figures mark an increase from the previous limits of $10,600 and $21,200 for 2026, impacting deductibles, coinsurance, and copayments for essential health benefits.

Traditionally published in the notice of benefit and payment parameters, these cost-sharing updates are now issued via a memo by January of the preceding year, maintaining transparency unless calculation methods change.

HHS Updates Civil Monetary Penalties for Statutory Violations

Effective January 28, 2026, HHS will adjust civil monetary penalties across various statutes. This change results from a 1.02598% increase due to cost-of-living adjustments. Key updates include HIPAA violations, Medicare Secondary Payer (MSP) violations, and Summary of Benefits and Coverage (SBC) penalties, impacting regulatory compliance significantly.

For HIPAA violations covering privacy and security, penalties vary by tier. For instance, Tier 1 (Lack of Knowledge) now has a minimum penalty of $145 and a maximum of $73,011, with an annual cap of $2,190,294. Similar adjustments impact other tiers, reflecting a critical focus on payer-provider regulatory compliance.

Medicare Secondary Payer violations will incur penalties such as $11,823 for discouraging plan enrollment and $1,512 for improper reporting. Insurers face a $1,443 penalty per instance for failing to provide an SBC, emphasizing underwriting and risk management obligations.

Legislative Changes in Pharmacy Benefit Management (PBM)

New legislation enacted on February 3, 2026, mandates reforms in the pharmacy benefit management (PBM) sector. PBMs must now disclose detailed information on drug pricing, spending, and compensation to group health plans, promoting transparency and regulatory compliance.

Group health plans, in turn, must provide summaries of this information to participants upon request. This move aligns with broader efforts to enhance accountability in healthcare administration and improve payer and carrier relations.

For further insights and historical context, refer to the Aon bulletin and past compliance briefings, essential for staying informed on industry changes.