Open enrollment season is a critical time for employers, and planning ahead ensures compliance and a smooth experience for your team. As we approach the 2026 plan year, several changes could impact how you design and administer your health benefits. From updated IRS limits to preventive care requirements, this checklist will help you navigate what’s new, what’s required, and what you should be communicating to your employees.
Review Your Plan Design
Affordability Under the ACA
Applicable Large Employers must continue to offer affordable health coverage that meets minimum value standards. For 2026, the affordability percentage increased to 9.96 percent, up from 9.02 percent in 2025. This adjustment gives employers slightly more room when setting employee contribution levels. To ensure compliance:
• Confirm at least one plan option meets the affordability threshold using IRS safe harbors
• Revisit employee contributions if needed
Out-of-Pocket Maximums
The ACA sets limits on how much employees can pay out-of-pocket for essential health benefits. For 2026, those limits are:
• $10,600 for self-only coverage
• $21,200 for family coverage
If you offer family coverage, make sure there is an individual out-of-pocket limit embedded in the plan that does not exceed $10,600. For High-Deductible Health Plans, confirm the out-of-pocket maximums fall below the HSA-compatible thresholds:
• $8,500 for self-only coverage
• $17,000 for family coverage
Preventive Care Requirements
Plans must cover recommended preventive services without any cost to the employee when received in-network. Updates for 2026 include expanded breast cancer imaging and patient navigation services for breast and cervical cancer screening. Ensure your plan reflects these new recommendations.
Check Contribution and Deductible Limits
Health FSA Limits
The 2026 contribution limit has not yet been released. Keep an eye out for IRS guidance, and once it’s announced:
• Make sure plan limits do not exceed the federal maximum
• Communicate the final limit during enrollment
Dependent Care FSA Limits
Effective January 1, 2026, the maximum annual contribution limit for dependent care flexible spending accounts increases to $7,500 (or $3,750 for married individuals filing separate tax returns).
• Decide if your plan will increase the annual maximum contribution
• Assess how the increased limit may impact the plan’s annual nondiscrimination testing results, particularly the 55% average benefits test
• Review your plan document to determine if updates are necessary due to the increased limit
• Communicate the new limit (if applicable) as part of the open enrollment process
HSA and HDHP Updates
New contribution and cost-sharing limits go into effect for 2026. Here’s a quick comparison:
Type
- HSA Self-only
- 2025 – $4,300
- 2026 – $4,400
- HSA Family
- 2025 – $8,550
- 2026 – $8,750
- Catch-up (55+)
- 2025 – $1,000
- 2026 – $1,000
- HDHP Deductible Self-only
- 2025 – $1,650
- 2026 – $1,700
- HDHP Deductible Family
- 2025 – $3,300
- 2026 – $3,400
- HDHP OOPM Self-only
- 2025 – $8,300
- 2026 – $8,500
- HDHP OOPM Family
- 2025 – $16,600
- 2026 – $17,000
Telehealth and HSAs
A permanent policy change allows HDHPs to cover telehealth services before the deductible is met without affecting HSA eligibility. Employers offering HDHPs should:
- Decide if your plan will cover telehealth without a deductible
- Update plan documents and communicate to employees
EBHRA Limit Increase
For 2026, the contribution limit for Excepted Benefit HRAs will rise to $2,200. Employers should:
- Determine how much to contribute
- Include the EBHRA amount in open enrollment materials
Compliance and Notices
Wellness Programs
If you offer wellness program incentives or surcharges, such as for tobacco use, you must meet nondiscrimination rules under HIPAA. Employers should:
- Ensure reasonable alternatives are available
- Clearly disclose these options in program materials
Mental Health Parity
Even though new MHPAEA regulations have been put on hold, plans are still required to maintain comparative analyses for nonquantitative treatment limitations. Work with your carrier or TPA to confirm documentation is current and available.
Required Notices to Include with Enrollment Materials
To streamline distribution and ensure compliance, include the following notices with your open enrollment materials:
- Summary of Benefits and Coverage (SBC): Required annually
- Medicare Part D Creditable Coverage Notice: Provide by October 15
- CHIP Notice: Required if your plan covers employees in states offering premium subsidies
- COBRA Initial Notice: Must be provided within 90 days of plan enrollment
- SPD or Summary of Material Modifications: Update if plan changes have been made
- HIPAA Special Enrollment Rights
- HIPAA Privacy Notice: Required at enrollment and every three years
- WHCRA Notice: Communicates rights to mastectomy-related benefits
- Patient Protection Notice: If plan requires a primary care provider designation
- Grandfathered Plan Notice: If applicable
- Summary Annual Report (SAR): If your plan files a Form 5500
- Wellness Program Notices: ADA and HIPAA disclosures must be included if your wellness program asks for medical information
- ICHRA Notice: Must be distributed at least 90 days before plan year begins if offering an ICHRA
Setting Your Team Up for a Successful Enrollment
Open enrollment is a significant opportunity to reinforce the value of your benefits program. It’s also a time to double-check compliance and make sure your communications are clear, complete, and timely. Take time now to review your plan design, confirm updated limits, and prepare the required notices.
As always, McConkey is here to guide you through the process and help you deliver a smooth and successful open enrollment season.
