Sarah Borders July 7, 2025 8 min read

Final Rules Amend Some 2026 ACA Figures

On June 23, 2025, a final rule amended the methodology for determining the Affordable Care Act’s (ACA) premium adjustment percentage, which is used to index the out-of-pocket (OOP) maximums for non-grandfathered medical plans and the §4980H penalties for applicable large employers (ALEs). With the 2026 premium adjustment percentage increasing under the revised methodology, the OOP maximums and ALE penalties previously announced last October are also increasing.

 

Applies To:

  • Non-grandfathered medical plans subject to the ACA’s annual OOP maximums
  • Applicable large employers (ALEs) subject to potential penalties under §4980H

 

Go Deeper:

With the premium adjustment percentage being increased for 2026, this is causing both the OOP maximums and ALE penalties to increase. Below is a table of the 2025 amounts along with the 2026 original and revised amounts.

  • The revised OOP applies to plan years beginning in 2026.
  • The revised ALE penalties apply to calendar year 2026.

 

2025 Amounts

2026 Original Amounts

(Announced Oct. 2024)

2026 Revised Amounts

(Announced Jun. 2025)

OOP Max per Person

$9,200

$10,150

$10,600

OOP Max per Family

$18,400

$20,300

$21,200

§4980H(a) ALE Penalty

$2,900
$241.67/mo.

$3,200
$266.67/mo.

$3,340
$278.33/mo.

§4980H(b) ALE Penalty

$4,350
$362.50/mo.

$4,800
$400.00/mo.

$5,310
$442.50/mo.

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Sarah Borders

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.

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