Open Enrollment is weeks away. Here's everything that changed for the 2027 plan year — and what to lock down now.

Nayya
August 26, 2026

There's a specific feeling to late August in this job.

Open Enrollment is still technically ahead of you. But every deadline that feeds it — plan design sign-off, rate loads, guide production, the comms calendar, manager talking points — has already started moving without asking your permission. The general guidance is that you want roughly 90 days of runway before your window opens. If yours opens in early November, that runway started about now.

One thing worth stating plainly, because it's the source of a lot of crossed wires in August: the window you're about to open is for the 2027 plan year. Coverage takes effect January 1. So every number below is the one your employees will be living inside about four months from now.

The good news: those numbers are finally all on the table. The Business Group on Health released its 2027 survey this week, the IRS published the last of the 2027 limits in July, and carriers have mostly stopped hedging.

So here's what actually changed, in plain language, with what each one means for the weeks you have left.

1. The trend number is 9.2% — and the forecast error is the real story

The Business Group on Health surveyed 127 employers covering 8.7 million U.S. lives. The median projected increase for 2027 — the year you're enrolling for — is 9.2% before plan design changes, dropping to about 8% after. For the year currently in progress, 2026, employers projected 8.5%, or 7% after changes.

Other forecasts cluster nearby but higher: Aon at 9.5%, PwC at 9% for group medical trend, and WTW at 11.1% before plan design changes — which would be the sharpest spike in nearly two decades.

But the more useful finding is about the forecasts themselves. Actual costs have exceeded employer projections for three consecutive years, and the gap has widened each year. In 2025, employers projected 6.8% and actual costs came in at 8.8%. Business Group on Health's own read is that current forecasts for 2026 and 2027 may be too optimistic. Cumulatively, costs are on track to be roughly 76% higher in 2027 than in 2018 — more than double the rate of general inflation over the same stretch.

What this means for HR teams: When you present trend to leadership, present the forecast error alongside the forecast. A 9.2% budget built on a methodology that has undershot three years running deserves a contingency conversation in September, not a surprise in Q2. And worth naming out loud: most employers are already too locked in to make structural changes for 2027. The teams that get real options for 2028 are the ones opening that conversation this fall.

2. The compliance numbers are set — and one of them crossed a line

In Revenue Procedure 2026-26, released July 21, the IRS set the ACA affordability percentage at 10.22% for plan years beginning in 2027, up from 9.96%. It's the highest the threshold has ever been, and the first time it has exceeded 10%. For a calendar-year 2027 plan using the federal poverty level safe harbor, the lowest-cost self-only option is automatically affordable at or below $135.92 per month. The percentage applies by plan year, so a non-calendar-year plan that started in 2026 keeps using 9.96% until it renews. Employer mandate penalty amounts also increased again for 2027.

On the account side, 2027 HSA contributions rise to $4,500 for self-only coverage and $9,000 for family coverage. The catch-up contribution for people 55 and older stays at $1,000, because it's fixed by statute rather than indexed. Qualifying high-deductible health plans need a minimum deductible of $1,750 self-only or $3,500 family, with out-of-pocket maximums capped at $8,700 and $17,400. Excepted-benefit HRAs go to $2,250.

Two details that catch teams out. First: if your HDHP deductible sits right at the current minimum, it has to rise to at least $1,750 or $3,500 for 2027, or the plan stops qualifying — and nobody enrolled in it can make new HSA contributions. Second: the health FSA limit for 2027 still hadn't been released as of late August. It was $3,400 for 2026, and it typically lands in the fall.

What this means for HR teams: You have more headroom on employee contributions than you had last year, which is precisely why it deserves a deliberate decision instead of a default. Confirm which safe harbor you're using, verify your lowest-cost self-only plan still clears the test, and document the calculation before your window opens rather than discovering it during ACA reporting. And treat every figure above as a two-place audit: these are the numbers most likely to be wrong in your enrollment platform and your printed guide at the same time. Check them against each other, not separately, and build your materials so the FSA figure can drop in late without a rebuild.

3. GLP-1 coverage is contracting, not expanding

This is the sharpest reversal in this year's data. Coverage of GLP-1s for weight management fell from 72% of surveyed employers to 60% year over year. Fourteen percent have dropped or will drop coverage in 2027. Not a single employer surveyed said they plan to add it.

Employers keeping coverage are tightening the guardrails — validating clinical eligibility through biometrics, requiring participation in a weight management program. Meanwhile 68% report rising utilization, pharmacy now accounts for about a quarter of total healthcare spend, and 95% of employers say they're concerned or very concerned about pharmacy costs.

What this means for HR teams: If your organization is changing GLP-1 coverage, that is the most emotionally loaded item in your entire enrollment communication, and it needs its own message — not a line in a comparison grid. Employees taking these medications will find out either from you, carefully, in September, or at a pharmacy counter in January. Also worth knowing: the direct-to-consumer market means many will continue treatment regardless. For them, a coverage change is a household budget conversation, not an access conversation. Communicating it that way is both more accurate and more humane.

4. Hospital prices and catastrophic claims are the structural story

Sixty-two percent of employers say hospital price increases are driving costs to a great or very great extent, and 48% say the same about outpatient facility costs. The mechanism is provider consolidation reducing competition and increasing pricing leverage over commercial plans.

On the condition side, cancer is the top cost driver for the fifth consecutive year, named by 70% of employers — up sharply from 58% last year. Musculoskeletal ranks second and cardiovascular third, with gastrointestinal and autoimmune conditions rising, both closely tied to specialty pharmacy growth. One quieter change to watch: the shift from bundled to unbundled maternity reimbursement in 2027 is expected to add both cost uncertainty and administrative complexity.

In response, 92% of employers expect to be using at least one value-based arrangement by 2027 — a center of excellence, a high-performance network, or an accountable care organization. About a third expect a transparent or new-generation pharmacy benefit manager in place by 2027, with nearly half considering the move in the two years after.

What this means for HR teams: Separate what you can influence from what you can't, and say so out loud. Unit prices from a consolidated health system are not something plan design fixes this year. Navigation, site of care, and steering toward high-quality providers are. Your communication to employees is more credible when it draws that distinction than when it implies everything is manageable.

5. The individual market shifted, and it lands on your desk

The enhanced ACA premium tax credits expired at the end of 2025, and the effects showed up fast. Average monthly marketplace enrollment could fall to roughly 17.5 million in 2026, down from 22.3 million in 2025. Average marketplace deductibles grew by about $1,000 per person as enrollees moved into higher-deductible plans. The steepest drop-off came from people just above the subsidy cliff.

What this means for HR teams: Some share of your employees has a spouse, an adult child, or a second household income that was relying on marketplace coverage that just got dramatically more expensive. Expect more dependent enrollment, more questions about spousal coverage and surcharges, and more employees for whom your plan is now the only affordable option in the household. Model dependent tier enrollment above your historical baseline, and make sure your eligibility rules and life-event documentation are current before the volume arrives.

If you only have time to sequence, not strategize

Most employer windows open in October or November, which leaves somewhere between six and ten weeks. Here's the order that consistently works:

Weeks 1–2: Lock the numbers. Final plan designs, contribution amounts, and every 2027 limit above — loaded in your enrollment platform and your materials, verified against each other rather than separately.

Weeks 3–4: Write the hard message first. Whatever is changing most — contributions, deductible, GLP-1 coverage, a plan going away — draft that communication before the general guide. It sets the tone for the entire season, and it's the one that will get read.

Weeks 5–6: Test the system, then test it as an employee. Log in against a real profile from each population. Confirm rates, eligibility, dependent tiers, and that your guidance experience is actually reachable from wherever employees start.

Weeks 7–8: Enable the humans. Manager talking points, an FAQ built from the questions you actually got last year, and one obvious front door for questions that isn't an individual person's inbox.

And if you're already thinking past this cycle to the 2028 plan year — the one whose design gets decided over the course of next year — good. That's the conversation that produces options instead of reactions. Consider this your nudge.