Employers finalizing health plan designs for 2027 are working with updated IRS limits. They are also working with a meaningfully different set of rules about what a high-deductible health plan (HDHP) can include while still preserving employee HSA eligibility.
The IRS published the 2027 HSA and HDHP parameters in Revenue Procedure 2026-24 on May 29. The contribution limits rise to $4,500 for self-only coverage, up $100 from $4,400, and to $9,000 for family coverage, up $250 from $8,750 - the first time the family limit has crossed that threshold.
HDHP minimum deductibles increase to $1,750 for self-only coverage and $3,500 for family coverage, with out-of-pocket maximums rising to $8,700 and $17,400, respectively. The catch-up contribution for individuals 55 and older remains $1,000. The excepted-benefit health reimbursement arrangement (HRA) limit rises to $2,250 for plan years beginning in 2027.
Any HDHP currently sitting at the 2026 minimum deductible of $1,700 must rise to at least $1,750 to remain HSA-qualifying. Plans that miss that update lose HSA compatibility for the new plan year, which means employees cannot make or receive contributions and employer contributions may carry tax consequences. That is the kind of downstream error that surfaces at tax time rather than during enrollment.
The more consequential shift for plan design comes from the One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, and clarified through IRS Notice 2026-5. Two provisions directly affect what an employer can offer alongside an HDHP without disqualifying employees from HSA participation.
First, the HDHP telehealth safe harbor is now permanent. During the COVID-19 pandemic, employers could offer pre-deductible telehealth coverage without breaking HSA eligibility, but that relief expired and was repeatedly extended on a temporary basis. The OBBBA ended that cycle. Employers can now offer first-dollar telehealth coverage under an HDHP, including behavioral health consultations and primary care visits, without affecting employees’ ability to contribute to their HSAs, for plan years beginning after December 31, 2024.
Second, direct primary care (DPC) arrangements are now HSA-compatible. Under a qualifying DPC arrangement, employees pay a flat monthly fee for access to primary care services. Until the OBBBA, that membership counted as disqualifying coverage. Beginning January 1, 2026, a DPC arrangement no longer disqualifies HSA eligibility, provided the monthly fee does not exceed $150 for individual coverage or $300 for family coverage.
The IRS confirmed in Rev. Proc. 2026-24 that those fee caps remain unchanged for 2027. Employees can also use HSA funds to pay the DPC membership fees tax-free, which is a meaningful addition to how the account can be used.
Both changes matter most in the context of what employers are trying to do with plan costs right now. With health benefit costs projected to rise 8.2% per employee in 2027, the steepest increase in 24 years, according to Marsh’s 2026 National Survey of Employer-Sponsored Health Plans, 59% of employers plan to make cost-cutting changes to health benefits, with higher deductibles as the primary lever. The well-documented problem with that approach is that employees on higher-deductible plans are already deferring care at measurable rates, with downstream effects on claim severity that can offset near-term savings.
The OBBBA provisions create a third option that was not cleanly available before. An employer can pair a higher-deductible plan with first-dollar telehealth coverage and a DPC arrangement, preserve HSA eligibility throughout, and add perceived access value without raising premiums. The DPC model covers routine primary care, chronic disease management, and preventive visits under a flat monthly fee. That is precisely the category of care that most commonly gets deferred when deductibles rise. The fact that employees can pay those DPC fees directly from their HSA reinforces, rather than competes with, the value of the account.
That plan design is worth walking through in a renewal conversation. The question of whether higher deductibles are the right tool for 2027 now has a more concrete answer than it did a year ago.
