What's changing for 2027: a $12,000 out-of-pocket max, narrower immigrant subsidy eligibility, Catastrophic plans and HSA limits

Out-of-pocket maximum

The individual out-of-pocket maximum rises to $12,000 in 2027, up from $10,600 in 2026. A rule that would have let some Bronze plans go as high as $15,600 was stayed by a court in July 2026.

Subsidy eligibility for lawfully present immigrants

Federal subsidy eligibility narrows in 2027 to lawful permanent residents, Cuban-Haitian Entrants and COFA migrants. Refugees, asylees, TPS holders, and work or student visa holders lose federal subsidy eligibility.

Catastrophic plans

Most people age 30 and older need a hardship or affordability exemption to buy a Catastrophic plan. A proposed expansion of eligibility was stayed in July 2026.

HSA limits

HSA contribution limits rise to $4,500 self-only (from $4,400) and $9,000 family (from $8,750). Marketplace Bronze and Catastrophic plans stay HSA-eligible, and HSA contributions lower MAGI, which can raise subsidy eligibility.

State help

Virginia Premium Savings starts Nov 1, 2026, for incomes of 138% to 250% of the federal poverty level. Rhode Island set aside $19 million in state funds.

Rules can shift with ongoing court cases. Check current CMS guidance before advising clients.