2026 Open Enrollment Checklist | At a Glance
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A quick-reference summary of key compliance changes employers should confirm before the 2026 plan year — inflation-adjusted limits, plan design updates, and required participant notices.
2026 Cost-Sharing & Contribution Limits
Limit | 2025 | 2026 | Change |
HSA Contribution — Self-only | $4,300 | $4,400 | +$100 |
HSA Contribution — Family | $8,550 | $8,750 | +$200 |
HSA Catch-Up (age 55+) | $1,000 | $1,000 | No change |
HDHP Min. Deductible — Self-only | $1,650 | $1,700 | +$50 |
HDHP Min. Deductible — Family | $3,300 | $3,400 | +$100 |
HDHP OOPM — Self-only | $8,300 | $8,500 | +$200 |
HDHP OOPM — Family | $16,600 | $17,000 | +$400 |
ACA OOPM — Self-only / Family | — | $10,600 / $21,200 | — |
Health FSA Limit | $3,300 | $3,400 | +$100 |
EBHRA Limit | $2,150 | $2,200 | +$50 |
ACA Affordability % | 9.02% | 9.96% | +0.94 pts |
Plan Design Action Items
• ACA Affordability: confirm at least one plan meets the 9.96% standard (use a safe harbor).
• OOPM Compliance: embed individual OOPM ($10,600) in family coverage; confirm HDHP limits.
• Preventive Care: confirm coverage of latest USPSTF/ACIP/HRSA items, incl. added breast cancer imaging & navigation services, with no cost sharing.
• Health FSA: cap pre-tax contributions at $3,400 and communicate to employees.
• HSA/HDHP: update plan limits and communicate new HSA contribution caps.
• Telehealth: decide (optional) whether to waive HDHP deductible for telehealth — now permanent under the One Big Beautiful Bill Act.
• EBHRA: set 2026 contribution (up to $2,200) and communicate.
• Wellness Surcharges: confirm HIPAA nondiscrimination compliance amid rising tobacco-surcharge litigation.
• MHPAEA NQTLs: confirm comparative analyses are current with issuer/TPA.
Open Enrollment Notices Checklist
• Summary of Benefits & Coverage (SBC) — annually
• Medicare Part D creditable coverage notice — annually, by Oct. 15
• Annual CHIP notice (where applicable)
• Initial COBRA notice — within 90 days of coverage
• SPD — new hires within 90 days; updates per 5/10-yr rule
• Notice of Patient Protections (if PCP designation required)
• Grandfathered plan notice (if applicable)
• HIPAA special enrollment rights notice
• HIPAA Privacy Notice (self-insured plans)
• WHCRA mastectomy-benefits notice — annually
• Summary Annual Report (SAR), if Form 5500 applies
• Wellness program notices (HIPAA & ADA, as applicable)
• ICHRA notice — 90 days before plan year (if applicable)
Also confirm: any 2026 plan changes are reflected in an updated SPD or SMM before open enrollment.
Provided by Cottingham & Butler. This overview is for general reference only and is not exhaustive or legal advice; consult legal counsel for guidance specific to your plans.
Source: Zywave, Inc. 2026 Open Enrollment Checklist.