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Maximum Out-of-Pocket Limits Released for 2026

Maximum Out-of-Pocket Limits Released for 2026

The Department of Health and Human Services (HHS) has recently released the 2026 Benefit Parameters, which specify the maximum out-of-pocket (OOP) limits for non-grandfathered plans starting in 2026. These limits are updated annually to account for inflation. In a commitment made in 2023, HHS assured that these updated amounts would be announced "by January of the year preceding the applicable benefit year," and they have fulfilled that commitment.

As mandated by the Affordable Care Act (ACA), non-grandfathered health plans must follow an annual limit on out-of-pocket expenses for essential health benefits. This regulation applies to both self-funded and fully insured plans. For the 2025 plan year, the OOP limits are set at $9,200 for self-only coverage and $18,400 for family coverage. These limits will see an increase in 2026 to $10,150 for self-only coverage and $20,300 for family coverage.

Here’s a summary of the out-of-pocket maximums for traditional plans for the 2025 and 2026 plan years:

OOPMAXes - Annual Out-of-Pocket Maximums

High-deductible health plans (HDHPs) with Health Savings Accounts (HSAs) come with their own set of limits, including out-of-pocket maximums, deductibles, and contribution limits. These specifics are generally released by the IRS each May. For instance, the 2025 HDHP/HSA limits weren’t released until May 9, 2024.

For those offering both traditional and HDHP/HSA plan options (that are not grandfathered), it’s crucial to comply with both sets of requirements. This means adhering to the lowest out-of-pocket maximum applicable. Importantly, the ACA stipulates that a per person (individualized/embedded) out-of-pocket maximum must not exceed the ACA limit, even within a larger (family) tier. This ensures that individual family members can access benefits without needing to hit the full family-tier amount.