On June 25, 2025, the U.S. Department of Health and Human Services (HHS) published final regulations that include changes to the calculations for certain cost sharing limits. The final regulations provide new 2026 out-of-pocket maximum limits (OOPMs) for non-grandfathered medical plans subject to the Affordable Care Act (ACA). The new limits are 4.4 percent higher than the initial 2026 OOPMs published late last year.
The IRS previously released Rev. Proc. 2025-19 on May 1, 2025, containing the 2026 high deductible health plan (HDHP) and health savings account (HSA) annual limits. The ACA’s OOPMs generally apply only to non-HDHPs, with a limited exception addressed later in our alert.
The following limits apply to plan years beginning during the applicable calendar year. Limits for 2025 and 2026 are shown for comparison purposes. This alert is relevant for all employers offering health coverage to their employees.
