2026 OOP Limits and ACA ALE Penalties Announced

On Wednesday, October 9, 2024, the federal government announced indexing for some health plan provisions for 2026.

The 2026 premium adjustment percentage will be 1.6002042901.  This impacts the total out-of-pocket limit for non-grandfathered health plans as well as Affordable Care Act (ACA) penalties for applicable large employers (ALEs). Below is a table of these limits for 2024, 2025, and now 2026.

	2024	2025	2026
Non-GF OOP • Limit Per person • Family cap	• $9,450 • $18,900	• $9,200 • $18,400	• $10,150 • $20,300
ALE Penalty §4980H(a) • This is the penalty for an ALE that fails to offer to 95% of “full-time” (and their dependents)	$2,970 ($247.50/mo)	$2,900 ($241.67/mo)	$3,200 ($266.67/mo)
ALE Penalty §4980H(b) • This is the penalty when coverage was not affordable, minimum value coverage and the FT employee obtained a Marketplace plan with a tax credit	$4,460 ($371.67/mo)	$4,350 ($362.50/mo)	$4,800 ($400.00/mo)

Your IMA Benefits team will review these each year with you to ensure you remain in compliance.

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

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