2027 Legislation & Compliance Dates

2027 HSA, HDHP, Excepted-Benefit HRA and DPC Limits

JANUARY 1, 2027

Why It's Important: HSA limits are $4,500 for self-only coverage and $9,000 for family coverage. The HDHP minimum deductible is $1,750 / $3,500, with an out-of-pocket maximum of $8,700 / $17,400. The excepted-benefit HRA limit is $2,250. HSA-compatible direct primary care monthly fees are $150 individual / $300 family. Applies to employers offering HSA-qualified HDHPs, excepted-benefit HRAs, or direct primary care arrangements.

Source: IRS Rev. Proc. 2026-24

ACA Affordability Percentage

PLAN YEARS BEGINNING IN 2027

Why It's Important: The required contribution percentage is 10.22%. Applies to applicable large employers and employers using affordability testing, including ICHRA affordability analysis where applicable.

Source: IRS Rev. Proc. 2026-26

ACA Employer Shared Responsibility Penalties

2027

Why It's Important: The annual §4980H(a) amount is $3,780, and the annual §4980H(b) amount is $5,670. Applies to applicable large employers.

Source: IRS Rev. Proc. 2026-22

ACA Annual Cost-Sharing Maximum

PLAN YEARS BEGINNING IN 2027

Why It's Important: The maximum is $12,000 for self-only coverage and $24,000 for other-than-self-only coverage. HSA-qualified HDHPs remain subject to the lower HSA statutory limits above. For family or other-than-self-only coverage, the self-only maximum also applies to each individual covered under the plan. Applies to non-grandfathered group health plans, including self-funded plans.

Source: CMS 2027 payment-parameter guidance

No Surprises Act Remittance-Code Requirements

JANUARY 1, 2027

Why It's Important: Plans and issuers must use specified RARCs on applicable remittance advice to noncontracted entities for No Surprises Act and Federal IDR claims. Plans may continue using the CARC they determine is appropriate unless CMS issues additional guidance. Applies to self-funded plans, TPAs, and payers processing affected out-of-network claims.

Source: CMS Federal IDR Operations Final Rule + implementation guidance

Medicare Part D Account-Based Arrangement Disclosure Exemption

JANUARY 1, 2027

Why It's Important: HRAs, FSAs, and HSAs are exempt from Medicare Part D creditable-coverage disclosure requirements. Employer prescription drug plans that are subject to the disclosure rules still must comply. Employers should distinguish account-based arrangements from prescription drug coverage when administering Part D notices.

Source: CMS CY 2027 MA and Part D Final Rule

Medicare Part D Creditable-Coverage Determination Methodology

2027

Why It's Important: Non-RDS group health plans using CMS’s simplified method must provide reasonable prescription drug coverage and retail pharmacy access, and cover at least 73% of participants’ prescription drug expenses on average. Employer-sponsored prescription drug plans should review plan design before issuing 2027 creditable/non-creditable coverage determinations.

Paper ACA Information Returns Due to IRS

MARCH 1, 2027

Why It's Important: Forms 1094-B/1095-B or 1094-C/1095-C, as applicable, are due for 2026 coverage. Paper filing generally is available only to filers that are not subject to the 10-return aggregate electronic-filing requirement or that receive an approved hardship waiver.

Medicare Part D Disclosure to CMS

MARCH 1, 2027

Why It's Important: Calendar-year prescription drug plans generally disclose creditable/non-creditable status within 60 days after the beginning of the plan year.

HIPAA Small-Breach Reporting to HHS, if Applicable

MARCH 1, 2027

Why It's Important: HIPAA-covered group health plans must report breaches of unsecured PHI affecting fewer than 500 individuals that were discovered during 2026 no later than 60 days after the end of the calendar year. A separate notice is required for each breach incident.

ACA Coverage-Statement Furnishing / Alternative-Furnishing Notice Deadline

MARCH 2, 2027

Why It's Important: Self-funded plan sponsors subject to §§6055 or 6056 may furnish applicable Forms 1095-B/1095-C or use the alternative furnishing method by posting the required clear, conspicuous, and accessible website notice by the applicable deadline and providing statements upon request within the required timeframe. Confirm final 2026 IRS form instructions before publication.

Electronic ACA Information Returns Due to IRS

MARCH 31, 2027

Why It's Important: Electronic Forms 1094-B/1095-B or 1094-C/1095-C, as applicable, are due. Electronic filing generally is required when the filer has 10 or more information returns in the aggregate.

RxDC Report for 2026 Data Due

JUNE 1, 2027

Why It's Important: Group health plans should coordinate data submissions and attestations with TPAs, carriers, PBMs, and other reporting entities.

PCORI Fee / Form 720 Due

AUGUST 2, 2027

Why It's Important: Applicable self-insured plans should use the IRS-published fee rate applicable to the plan year when available. July 31, 2027 falls on Saturday.

Form 5500 Due for Calendar-Year Plans

AUGUST 2, 2027

Why It's Important: Applies to ERISA plans subject to Form 5500 reporting. July 31 falls on Saturday. Extension procedures remain available.

Summary Annual Report Generally Due

SEPTEMBER 30, 2027

Why It's Important: Applies to calendar-year ERISA plans for which a SAR is required, assuming no Form 5500 extension.

Medicare Part D Creditable/Non-Creditable Coverage Notice

BEFORE OCTOBER 15, 2027

Why It's Important: Applicable prescription drug plans notify Medicare-eligible individuals before the annual Part D enrollment period and at other required events.

Gag Clause Prohibition Compliance Attestation

DECEMBER 31, 2027

Why It's Important: Group health plans, including self-funded plans, attest to compliance with the statutory gag-clause prohibition.

Transparency in Coverage Requirements

ONGOING

Why It's Important: Non-grandfathered group health plans should maintain required public machine-readable files and update applicable files monthly, and maintain the required internet-based cost-comparison/self-service tool for covered items and services. Plans should coordinate compliance with TPAs, networks, and other service providers while maintaining plan-level oversight.

Calendar-date note: Tax-form and ERISA deadlines should be rechecked against final 2026 reporting instructions and any agency relief before publication of the final calendar.

MHPAEA / NQTL Enforcement

2027 WATCH ITEM

Why It's Important: Existing MHPAEA and CAA 2021 NQTL requirements remain in effect, while newer 2024 rule provisions are not being enforced during ERIC litigation. DOL’s 2026 priorities include treatment limitations, medical-necessity reviews, and network adequacy. Keep NQTL comparative analyses current, review plan design and administration against DOL’s identified enforcement priorities, and continue monitoring the ERIC litigation and agency guidance.

Federal IDR Registry

EXPECTED SPRING 2027, SUBJECT TO CMS IMPLEMENTATION

Why It's Important: CMS expects IDR Registry functionality in spring 2027 under the 2026 Federal IDR Operations Final Rule. Applicability dates depend on CMS announcing availability and the rule’s implementation timeline. TPAs and plans using Federal IDR should monitor CMS implementation notices and prepare registration/data processes.

CAA 2026 PBM Reform Implementation

2027 READINESS YEAR

Why It's Important: Key PBM contract and reporting requirements generally begin for plan years on or after August 3, 2028, with calendar-year plans starting January 1, 2029. Implementing regulations are due by August 3, 2027. Treat 2027 as a rulemaking, contracting, and implementation-readiness year. Review PBM contract terms, data access and audit rights, rebate/remuneration definitions, reporting capabilities, and renewal timing.

Federal PBM / Transparency Rulemaking

NO CONFIRMED 2027 DEADLINE

Why It's Important: Additional federal PBM compensation and health-plan price-transparency requirements have been proposed or remain under development. Monitor final rules before assigning any calendar deadline.

HIPAA Security Rule Cybersecurity Rulemaking

NO CONFIRMED 2027 DEADLINE

Why It's Important: HHS has proposed expanded cybersecurity, documentation, risk-management, and business-associate requirements for health plans. The rule is not yet final, and current HIPAA Security Rule requirements remain in effect. Monitor final rulemaking and its implementation period rather than assigning a 2027 compliance date.

Advanced Explanation of Benefits (AEOB)

NO FIXED 2027 COMPLIANCE DATE

Why It's Important: AEOB requirements remain deferred pending rulemaking and data-transfer standards. No fixed 2027 compliance date has been established. Treat as a watchlist item only and monitor federal rulemaking and implementation guidance for future applicability dates.

Summary of Benefits and Coverage (SBC)

ENROLLMENT AND RENEWAL; UPON REQUEST; ADVANCE NOTICE FOR QUALIFYING MIDYEAR MATERIAL MODIFICATIONS

Why It's Important: Provide at enrollment and renewal, upon request, and in advance of qualifying midyear material modifications.

Summary Plan Description (SPD) / Summary of Material Modifications (SMM)

SPD AND SMM TIMING VARIES

Why It's Important: SPD generally must be provided within 90 days after coverage begins, or within 120 days for a new ERISA plan. SMMs are generally due within 210 days after the end of the plan year, or within 60 days for material reductions in benefits.

HIPAA Notice of Privacy Practices

AT REQUIRED DISTRIBUTION POINTS; REMINDER AT LEAST EVERY 3 YEARS; AFTER MATERIAL REVISION

Why It's Important: Provide at required distribution points, remind participants of availability at least every three years, and redistribute after material revision as required.

HIPAA Special Enrollment Rights Notice

AT OR BEFORE INITIAL ENROLLMENT OPPORTUNITY

Why It's Important: Provide at or before the time an employee is initially offered the opportunity to enroll.

CHIPRA Premium Assistance Notice

ANNUALLY

Why It's Important: Provide annually to employees residing in states that provide Medicaid or CHIP premium assistance.

Women’s Health & Cancer Rights Act (WHCRA) Notice

AT ENROLLMENT AND ANNUALLY

Why It's Important: Provide at enrollment and annually.

Health Insurance Marketplace Notice

FOR NEW EMPLOYEES, GENERALLY WITHIN 14 DAYS OF START DATE

Why It's Important: Generally provide to new employees within 14 days of start date.

COBRA General / Election Notices

EVENT-DRIVEN

Why It's Important: Timing is event-driven based on initial coverage and qualifying-event timelines.

Medicare Part D Creditable Coverage Notice

BEFORE OCTOBER 15 AND AT OTHER REQUIRED EVENTS

Why It's Important: Provide before October 15 and at other required enrollment or coverage-status events for applicable prescription drug coverage.

• IRS Rev. Proc. 2026-24 — 2027 HSA, HDHP, DPCSA, and excepted-benefit HRA amounts
• IRS Rev. Proc. 2026-26 — 2027 ACA required contribution percentage
• IRS Rev. Proc. 2026-22 — 2027 employer shared responsibility payment amounts
• CMS — 2027 Premium Adjustment Percentage and Maximum Annual Limitation on Cost Sharing guidance
• CMS — Contract Year 2027 Medicare Advantage and Part D Final Rule
• CMS — Federal Independent Dispute Resolution Operations Final Rule and implementation timeline
• CMS — Creditable Coverage guidance for employers and plan sponsors
• DOL/HHS/Treasury — Statement regarding enforcement of the 2024 MHPAEA Final Rule
• DOL — 2025 MHPAEA Report to Congress

Research note: This is a planning reference, not legal advice.