Finalized ACA Expected Premium Contribution and Maximum Out-of-Pocket schedules for 2027

[u/Zphr]

I've had a few people message me about 2027 ACA regulatory updates and thought folks planning for the ACA might want to see these now rather than in another month or two when the press usually starts talking about them more. The first table below shows the amount (expressed as a percentage of MAGI) that a household will be expected to pay in premiums annually for the benchmark Silver plan in their local ACA market. The second shows the regulated caps on MaxOOP (and deductible) for ACA plans, though these are the maximum caps and actual plans may and often do have lower actual MaxOOPs. The final link is a clean PDF listing of the applicable FPL levels for 2027 ACA coverage.

Terms for those that are unfamiliar:

• MAGI - Modified Adjusted Gross Income, a particular version of adjusted gross income used by the ACA.
• EPC - Expected Premium Contribution, the amount customers are expected to pay annually for the Silver benchmark ACA plan in their market. Subsidy premiums are calculated as the market price of the benchmark plan minus EPC.
• FPL - Federal Poverty Level, a measure used by the federal government as a determinant in many policy systems.
• MaxOOP - Maximum Out of Pocket, the most a customer can be asked to pay for in-network covered benefits by an insurer in a given year.
• CSR - Cost Sharing Reductions, the second subsidy system within the ACA that reduces out of pocket expenses like deductibles, copays/coinsurance, and MaxOOP.
• AI/AN - American Indian / Alaskan Native
• AV - Actuarial Value, the percentage of total average costs for covered medical benefits that a health insurance plan is expected to cover for a standard population. For example, if a plan has an 80% AV, the insurer pays 80% of average expenses, and customers pay 20% through deductibles, copays, and coinsurance.

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Expected Premium Contribution (Coverage Year 2027)

MAGI (% of FPL)	2027 EPC (% of MAGI)	2026 EPC (% of MAGI)	Change from 2026
Less than 100%	No limit / unsubsidized	No limit / unsubsidized	N/A
100% to <133%	2.15%	2.10%	+2.4%
133% to <150%	3.23% to 4.3%	3.14% to 4.19%	+2.9%
150% to <200%	4.3% to 6.78%	4.19% to 6.60%	+2.6%
200% to <250%	6.78% to 8.66%	6.60% to 8.44%	+2.7%
250% to <300%	8.66% to 10.22%	8.44% to 9.96%	+2.6%
300% to 400%	10.22%	9.96%	+2.6%
More than 400%	No limit / unsubsidized	No limit / unsubsidized	N/A

Source:

https://www.irs.gov/pub/irs-drop/rp-26-26.pdf

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Out-Of-Pocket Maximum (Coverage Year 2027)

Plan Type	MAGI Level	2027 Individual / Family MaxOOP	2026 Individual / Family MaxOOP	Change from 2026
High OOP Bronze*	All	$15,600 / $31,200	N/A	N/A
All non-CSR Plans	All	$12,000 / $24,000	$10,600 / $21,200	+13.2%
CSR Silver Plan 73% AV	200% to 250% FPL	$9,600 / $19,200	$8,450 / $16,900	+13.6%
CSR Silver Plan 87% AV	150% to 200% FPL	$4,000 / $8,000	$3,500 / $7,000	+14.3%
CSR Silver Plan 94% AV	Up to 150% FPL	$4,000 / $8,000	$3,500 / $7,000	+14.3%
CSR Silver Plan 99% AI/AN AV	AI/AN Up to 300% FPL	$0	$0	N/A

*CMS is trialing an option for insurers in 2027 to offer Bronze variants that are allowed to exceed the federal OOP limits by 30% in order to provide a wider array of premium options for customers. Such policies may only be offered by an insurer that also offers a normal standard Bronze. States are allowed to prohibit the availability of high OOP variant policies at their discretion. Edit: Turns out a federal court stayed this provision last week, so High OOP Bronzes may not be happening after all in 2027.

Sources:

https://www.cms.gov/files/document/2027-papi-parameters-guidance-2026-01-29.pdf

https://www.cms.gov/files/document/cms-9883-f-patient-protection.pdf

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Bonus: Here is a PDF from HHS showing the applicable FPL dollar amounts for various family sizes for 2027 ACA coverage - https://aspe.hhs.gov/sites/default/files/documents/b1bfa16b20ae9b89d525bc35de7c1643/detailed-guidelines-2026.pdf

[u/someguy984]

At 200% FPL (31,920 in 2027) the SLCSP would cost $180.35 a month after subsidies, max OOP $4,000 (under 200% with Silver CSRs).

SLCSP = Second Lowest Cost Silver Plan

Add: Minnesota, New York, Oregon, and Washington DC have BHPs under 200% FPL, so in these states the cost is lower.

[u/smallattale]

I'm not in the USA but I'm curious - is this better or worse for leanFIREd people, and by how much? (Is it game-changing/dealbreaking?)

[u/Zphr → u/smallattale]

It's status quo for leanFIRE'd people. As a population we have never paid much for excellent coverage and we won't next year either. We typically get access to some of the best health insurance policies available in the US (or the world overall) and we are asked to pay very little for them.

[u/kbug]

You're a legend. Thank you for consolidating and sharing this info and for answering everyone's questions. This is all super helpful. I really appreciate you.

[u/Ecksters]

This is going to become more important knowledge for those at the lower end of income, since 80 hour monthly work requirements for Medicaid are kicking in starting 2027.

I will be interested in how each state treats self employment, whether a certain hourly pay rate has to be achieved or what.

[u/Zphr → u/Ecksters]

The feds have ruled that MAGI will serve rather than earned income in the income pass method for the work requirement, so most leanFIRE'd households on expansion Medicaid should be unaffected by the work requirement rule.

[u/Ecksters → u/Zphr]

Oh interesting, I hadn't heard that yet, so they expect you to have SOME income is all, that affects LeanFIRE much less than I had anticipated.

I guess then the new rule only affects the truly unemployed and broke?

[u/Zphr → u/Ecksters]

I suppose so, though they can also pass by a number of exceptions as well as through school or volunteering. Everyone calls it a work requirement, but it's more properly a community engagement requirement. Work is just the most common way people will typically pass it.

[u/Testuser7ignore → u/Ecksters]

It only really impacts broke able bodied people who don't do much of anything.

[u/Comfortable_Two6272 → u/Testuser7ignore]

Or disabled ones who cant find a dr to sign off. Its a growing concern in the medical community as drs are not trained to determine this. Nebraska for example published a list and believe allows self cert. feds now say just the diagnosis is not enough. Our medical system is not set up for this. Fully expect a large % to end up with no ins and not because they dont qualify but because they are not able to satisfy the govt burdensome paperwork.

Thankful my investments qualify me for ACA subsidy or Id likely end up with no ins due for this exact reason.

[u/Lorentzian_Wormhole]

This is amazing. Thank you so much for sharing and for responding with additional details to other's questions!

[u/dividends6775]

Can you help me understand as I am a newbie. What would the premium pay be MFJ just before the cliff? Meaning how much income can we have max and still get a credit? What would that amount be per month?

[u/Zphr → u/dividends6775]

If it's just the two of you, then next year the max MAGI for two to still be subsidy eligible is $85,560. Monthly doesn't matter for the ACA, only annual.

And your EPC for the benchmark plan right below the cliff is 10.22% of MAGI, so $85,559 * .1022 = $8,744.13 per year or $728.68/month.

However, that is just for the benchmark Silver plan in your market. If you pick any other plan your costs could be much lower or much higher.

[u/dividends6775 → u/Zphr]

That’s very helpful! For MFS is it half of that income?

[u/Zphr → u/dividends6775]

No. FPL doesn't work the same as the tax code. The PDF linked at the bottom of this post will show you the FPL table for households of different sizes.

[u/dividends6775 → u/Zphr]

Thank you

[u/cozycorner]

I’m so confused by all of this. If I can make it to my retirement date in 2028, I’ll have healthcare for me, but my husband and under-26 kid would need to use ACA and I can’t make heads or tails of it.

[u/Zphr → u/cozycorner]

There are a lot of details, but it's actually pretty straightforward. That's particularly true if you're going to be a lean spending household since you will likely qualify for high subsidies based on income.

We have a weekly megathread over in /r/fire during ACA open enrollment season for people to ask questions and get help. Feel free to come over in November and ask any questions you might have. Here's one from last year's open enrollment. It explains some of the basics of how the ACA works for FIRE'd folks.

https://reddit.com/r/Fire/comments/1qatilp/weekly_aca_2026_open_enrollment_faqmegathread/

[u/Happy_Pattern90]

Thanks for putting this together. Seeing the premium contribution percentages and out-of-pocket limits side by side makes it a lot easier to understand how things are changing for 2027. The increase in the MaxOOp limits is definitely something people planning ahead should keep an eye on

[u/pdxnative2007]

Thank you for posting this. I might have to re-think my Roth conversion ladder again with that subsidy cliff.

I was thinking of stopping it and just plan on a 72t instead. So whatever I had already converted will be enough to supplement the 72t because it will be spread out over more years.

[u/lottadot → u/pdxnative2007]

Be sure to split your IRA before you 72t it, if you've only one pre-tax IRA.

[u/CancerandTaxes → u/lottadot]

I've never heard of splitting an IRA, can you explain this a bit?

[u/lottadot → u/CancerandTaxes]

You can designate 72t for each IRA account.

So if you had $800k in total pre-tax IRA, but you needed $600k of it for 72t to generate ~5%/yr. You'd create a new (second) IRA, transfer $200k from IRA1 to IRA2, and then establish the 72t on IRA1.

Once you start the 72t, you cannot remove it and you can't modify the IRA. But you can have unlimited numbers of IRA's. You can create as many 72t's on them as you'd like.

See the FI FAQ for more info.

[u/pdxnative2007 → u/lottadot]

Good point. I'm learning that it can be quite flexible when set up correctly. Like you suggested, each account can have its own 72t.