Overview
The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2026-24) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and excepted benefit health reimbursement arrangements (HRAs) for 2027. In addition, this year’s guidance includes inflation-adjusted limits for the aggregate fees that can be made available under direct primary care service arrangements (DPCSAs), which were first made available under the One Big Beautiful Bill Act (OBBBA) (see our client alert here). Most of the dollar limits currently in effect for 2026 will change for 2027.
The table below compares the applicable dollar limits for HSAs, HDHPs, and excepted benefit HRAs for 2026 and 2027.
| HEALTH AND WELFARE PLAN LIMITS | 2026 | Δ | 2027 |
|---|---|---|---|
| HDHP – maximum annual out-of-pocket limit (excluding premiums) | |||
| Self-only coverage | $8,500 | ↑ | $8,700 |
| Family coverage | $17,000 | ↑ | $17,400 |
| HDHP – minimum annual deductible | |||
| Self-only coverage | $1,700 | ↑ | $1,750 |
| Family coverage | $3,400 | ↑ | $3,500 |
| HSA – annual contribution limit | |||
| Self-only coverage | $4,400 | ↑ | $4,500 |
| Family coverage | $8,750 | ↑ | $9,000 |
| Catch-up contributions (ages 55 and older) | $1,000 | ═ | $1,000 |
| Excepted benefit HRA | |||
| Annual contribution limit | $2,200 | ↑ | $2,250 |
| DPCSA | |||
| Aggregate monthly fees for DPCSA that covers one individual | $150 | ═ | $150 |
| Aggregate monthly fees for DPCSA that covers more than one individual | $300 | ═ | $300 |
Next steps
Plan sponsors should update payroll and plan administration systems for the 2027 cost-of-living adjustments and incorporate the new limits in relevant participant communications, such as open enrollment and communication materials, plan documents, and summary plan descriptions.
For further information about applying the new HSA, HDHP, excepted benefit HRA, and DPCSA plan limits for 2027, please contact your regular McDermott lawyer or one of the authors below.