Open enrollment for 2026 plan years carries the largest single-year jump in the ACA’s affordability threshold since the law took effect. If you’re waiting until October to start reviewing plan design, you’re not early — you’re behind.
The 2026 Rules Changed More Than Usual
Two federal changes are reshaping open enrollment prep this year, and both affect how you set contributions and design plans.
The IRS raised the ACA affordability percentage from 9.02% to 9.96% for plan years beginning in 2026, according to SHRM. That’s the highest the threshold has ever been, which gives applicable large employers more room on employee contributions — but only if you recalculate using the right safe harbor.
At the same time, the maximum out-of-pocket limit for non-grandfathered plans rose to $10,600 for self-only coverage and $21,200 for family coverage, per KFF. Plan documents, summaries of benefits and coverage, and enrollment materials all need to reflect the new number before employees start choosing coverage.
Neither change is optional to act on. Both change the math on your group health insurance plan design for next year.
Five Things to Handle Before Enrollment Opens
1. Recheck your affordability math against 9.96%.
Employers can use one of three IRS safe harbors — the W-2 method, the rate-of-pay method, or the federal poverty line method — to confirm at least one plan option qualifies as affordable. Run the numbers now, not during open enrollment week, because a miscalculation here is what triggers IRS penalty letters later.
2. Confirm your plan design matches the new out-of-pocket maximum.
If benefits changed for the 2026 plan year, employees need an updated Summary Plan Description or a Summary of Material Modifications. Don’t let a carrier’s default paperwork slide through unreviewed.
3. Line up your required notices.
The Summary of Benefits and Coverage has to go out with enrollment materials, and if coverage renews automatically, timing rules still apply. This is the part that gets rushed every year, and it’s the easiest to fix with a checklist built in August instead of October.
4. Build a communication timeline employees will actually follow.
One all-staff email isn’t a strategy. Multiple touches — an initial notice, a plain-language explainer, a reminder, a final deadline push — give employees time to understand what changed and why. A benefits education meeting partway through the window gives people a chance to ask questions before they’re rushed into a decision.
5. Make sure your systems can carry the load.
Manual enrollment tracking and version-controlled spreadsheets fall apart fast once you’re juggling new hires, life events, and open enrollment elections in the same month. Integrated administration platforms cut down the back-and-forth between HR, payroll, and carriers.
Why This Isn’t a One-Person Job
Most brokers show up at renewal with a set of quotes and disappear until next year. That leaves the HR director holding the compliance risk, the communication plan, and the employee questions alone.
Victor Insures You works differently. We represent employers, not carriers, which means we’re reviewing your plan design, checking your affordability math, and pressure-testing your carrier’s numbers before open enrollment opens — not after something breaks. Read more about how we work with growing employers.
If your current broker went quiet after your renewal call, that’s worth a second look before this year’s enrollment window opens. Start the conversation or book a meeting to get your 2026 plan design reviewed now, while there’s still time to fix what needs fixing.
Frequently Asked Questions
When should HR start preparing for open enrollment?
Most organizations start serious prep 60–90 days before their enrollment window opens. That gives enough time to confirm affordability calculations, update plan documents for new cost-sharing limits, and build a communication timeline instead of sending one rushed email the week enrollment starts.
What is the ACA affordability threshold for 2026?
The IRS set the 2026 ACA affordability percentage at 9.96%, up from 9.02% in 2025. This means an employee’s required contribution for the lowest-cost self-only plan that provides minimum value can’t exceed 9.96% of their income under whichever IRS safe harbor the employer uses.
What’s the difference between an SBC and an SPD?
A Summary of Benefits and Coverage (SBC) is a standardized snapshot of plan costs and coverage that must go out with enrollment materials. A Summary Plan Description (SPD) is the fuller plan document. When benefits change year to year, employees need an updated SPD or a Summary of Material Modifications alongside the SBC.
Do employers need to update out-of-pocket maximums for 2026?
Yes. The maximum out-of-pocket limit for non-grandfathered group health plans rose to $10,600 for self-only coverage and $21,200 for family coverage for 2026 plan years. Plan documents, SBCs, and enrollment materials all need to reflect the updated figures before employees enroll.
Should employers switch carriers during open enrollment?
Not automatically. Carriers tend to offer better rates to groups that have stayed put, and switching often signals higher risk to underwriters. But if your current plan’s costs have climbed past what makes financial sense, a strategic shopping round — backed by real negotiation with your current carrier first — is worth pursuing.