Your renewal packet lands in a few weeks, your broker wants decisions by October, and the numbers changed more this year than they have in a decade. The Affordable Care Act affordability threshold just jumped to its highest level ever, every HSA and FSA limit moved, and at least five federal notices need to land in employees' hands on specific schedules — one of them before October 15. If you sponsor a group health plan, this is the year to run open enrollment like a compliance project, not a paperwork ritual.
This checklist walks through what changed for plan years starting January 1, 2026, which notices you must distribute and when, and the renewal timeline that keeps a small employer out of trouble.
What Changed for 2026 Plan Design
Before you touch enrollment materials, confirm your plan reflects the new inflation-adjusted limits. Getting these wrong means payroll deductions, HSA contributions, or affordability calculations built on last year's numbers.
ACA affordability hits a record 9.96%
If you are an applicable large employer (ALE) — generally 50 or more full-time employees including full-time equivalents in the prior calendar year — you must offer affordable, minimum-value coverage to full-time employees and their dependents or face potential penalties. Coverage counts as affordable when the employee's required contribution for the lowest-cost self-only minimum-value plan does not exceed 9.5 percent of household income, as adjusted each year for inflation.
For plan years beginning in 2026, the IRS set that percentage at 9.96 percent, up sharply from 9.02 percent for 2025 and the highest it has ever been. Practically, that gives ALEs more room: you may be able to ask employees to contribute more toward premiums in 2026 and still pass the affordability test. Since you rarely know an employee's actual household income, the IRS offers three safe harbors — Form W-2 wages, rate of pay, and the federal poverty line — to test affordability with data you actually have.
Out-of-pocket maximums rise — and the embedded limit still applies
For 2026, the ACA caps total enrollee cost sharing for essential health benefits at $10,600 for self-only coverage and $21,200 for family coverage. The self-only cap applies to every covered individual, even someone enrolled in a family plan — so if your family out-of-pocket maximum exceeds $10,600, the plan must embed an individual cap of no more than $10,600 inside the family tier.
High-deductible health plans that preserve HSA eligibility face tighter caps: $8,500 self-only and $17,000 family for 2026.
HSA, HDHP, and health FSA limits all increase
The 2026 figures, confirmed in IRS guidance:
- HSA contributions: $4,400 self-only (up $100) and $8,750 family (up $200). The $1,000 catch-up contribution for account holders age 55 and older is fixed by statute and does not change.
- HDHP minimum deductibles: $1,700 self-only and $3,400 family.
- Health FSA salary reductions: $3,400, up from $3,300. Your plan may set a lower cap but cannot exceed this one.
Telehealth under HDHPs is permanently safe for HSAs
A pandemic-era rule that let high-deductible plans cover telehealth before the deductible without killing HSA eligibility expired, then got a permanent rescue: the One Big Beautiful Bill Act now lets HDHPs waive the deductible for telehealth and other remote care indefinitely, starting with plan years beginning in 2025. The relief is optional — you can still run telehealth through the deductible — but if your plan takes it, tell participants through an updated Summary Plan Description (SPD) or Summary of Material Modifications (SMM).
Excepted-benefit HRA limit: $2,200
Employers of any size can offer an excepted benefit HRA (EBHRA) to reimburse out-of-pocket medical costs alongside a traditional plan offer. The maximum newly available amount rises to $2,200 for 2026 plan years.
Two design reviews small employers skip
First, preventive care: non-grandfathered plans must cover newly recommended preventive services without cost sharing starting with the plan year that begins on or after the one-year anniversary of the recommendation. For 2026 that includes expanded first-dollar coverage tied to mammography follow-up imaging and patient navigation services for breast and cervical cancer screening. Confirm with your carrier or third-party administrator that the plan reflects current recommendations.
Second, tobacco surcharges and wellness rewards: HIPAA nondiscrimination rules require health-contingent wellness programs to offer a reasonable alternative standard and to disclose it in every document describing the surcharge or reward. Tobacco-premium surcharges have drawn a wave of class-action scrutiny, so if you charge smokers more, verify the alternative-standard language is actually in your materials before enrollment opens.
The Notices You Must Distribute (and When)
Open enrollment is the natural moment to bundle the annual disclosures. Some must go out at enrollment; others are annual notices you can include for convenience. Group them and you mail once instead of four times.
Summary of Benefits and Coverage (SBC)
Every applicant and enrollee gets an SBC at open enrollment or renewal, using the federal template. For insured plans the carrier usually prepares it and you distribute it; for self-funded plans the plan administrator owns both jobs. Verify the SBC matches the plan you are actually offering — benefit changes that never made it into the SBC are a classic audit finding.
Medicare Part D creditable-coverage notice — due before October 15
If your plan includes prescription drug coverage, you must tell Medicare-eligible participants each year whether that coverage is creditable — at least as good as standard Medicare Part D. There is no penalty for offering non-creditable coverage, but individuals who skip Part D while covered by a non-creditable plan can owe permanently higher Part D premiums later, so they need the facts.
The notice goes out at enrollment, when creditable status changes, on request, and every year before October 15, when Medicare's annual election period begins. Model notices in English and Spanish are available from the Centers for Medicare and Medicaid Services. Most employers tuck this notice into the open enrollment packet; regulators treat that as covering the following 12 months as long as drug coverage does not materially change.
Annual CHIP premium-assistance notice
If any employee lives in a state that subsidizes employer coverage for low-income children and families through Medicaid or CHIP, you must send those employees the annual premium-assistance notice. The Department of Labor updates its model notice regularly — pull the current version rather than reusing last year's file.
WHCRA notice — at enrollment and annually
Plans covering mastectomies must disclose participants' rights to reconstruction-related benefits under the Women's Health and Cancer Rights Act when they enroll and once a year after that. Open enrollment is the standard annual slot.
HIPAA privacy notice — check the three-year clock
Health plans must give new enrollees a Notice of Privacy Practices at enrollment and, at least once every three years, either redistribute it or notify participants that it is available and how to get a copy. Sponsors of fully insured plans that do not handle protected health information for plan administration generally leave this duty to the carrier — but if your team touches PHI beyond enrollment and summary data, the obligation is yours. If you are unsure when you last sent one, this enrollment season is the time.
HIPAA special-enrollment and patient-protection notices
Eligible employees must learn about their HIPAA special-enrollment rights at or before enrollment — typically via the SPD or carrier benefit summary. If your plan requires participants to designate a primary care provider, you must also distribute the ACA patient-protections notice (free PCP choice, direct OB-GYN access) whenever the SPD or benefit description goes out.
COBRA initial notice and the SPD
Plans of employers with 20 or more employees owe new participants an initial COBRA notice within 90 days after coverage begins; it can live inside the SPD. The SPD itself is due to new participants within 90 days of coverage, must be refreshed every five years when amended (every ten years if never amended), and any 2026 benefit change belongs in an updated SPD or SMM. Do not run open enrollment on a stale SPD and promise to update it later.
ICHRA notice — 90 days before the plan year
Reimbursing employees for individual-market coverage through an individual coverage HRA? Eligible participants need the ICHRA notice — including how the arrangement interacts with premium tax credits — at least 90 days before each plan year. For calendar-year plans that means by October 2. Open enrollment materials can carry it only if they go out in time.
Wellness program notices
Health-contingent wellness programs need the HIPAA alternative-standard disclosure in all program materials, and programs collecting health information or requiring medical exams need an ADA notice explaining what is collected, who sees it, and how it stays confidential. Deliver both before employees hand over health data or sit for screenings.
The Renewal Timeline to Start Now
Working backward from a January 1 plan year, here is a realistic calendar for a small team with no dedicated benefits staff:
- Mid-September (now): Confirm 2026 limits with your broker or carrier — affordability percentage, out-of-pocket maximums, HSA and FSA caps, EBHRA amount. Decide whether your HDHP waives the deductible for telehealth. Pull current model notices (CHIP, Part D, COBRA, WHCRA, ICHRA) instead of recycling files.
- By October 2: Deliver the ICHRA notice if you offer one — the 90-day rule for calendar-year plans.
- Before October 15: Distribute Medicare Part D creditable-coverage notices to all Medicare-eligible participants.
- October–November: Hold open enrollment. Include the SBC for each plan option, the CHIP notice, the WHCRA notice, HIPAA special-enrollment and patient-protection language, and wellness notices. Confirm the SPD or an SMM reflects every 2026 design change.
- December: Lock payroll for January — new premium splits, FSA elections capped at $3,400, HSA elections at the 2026 limits. Calendar the retirement-plan amendment deadline below.
- By December 31, 2026: Adopt written amendments bringing qualified retirement plans into compliance with the CARES Act, SECURE 1.0, and SECURE 2.0. Most calendar-year plans face this hard deadline under IRS guidance, and open enrollment season is the right time to confirm with your recordkeeper that the paperwork is queued — not to discover in December that nobody drafted it.
One more year-end item for the finance calendar: self-funded plan sponsors should confirm the mental-health-parity comparative analysis for nonquantitative treatment limits is current for 2026. The 2024 final rule tightening those analyses is on enforcement hold, but the underlying statutory duty to maintain one is not — ask your carrier or TPA for written confirmation.
Track the Money Behind the Benefits
Benefits compliance is half paperwork and half payroll math. Affordability safe harbors run off W-2 wages or rates of pay, FSA and HSA caps gate pre-tax deductions, tobacco surcharges change per-paycheck premiums, and ICHRA reimbursements need clean substantiation. When those figures live in scattered spreadsheets, the January payroll run becomes an archaeology project — and a miscoded pre-tax deduction can quietly breach a limit you just communicated to employees.
Keeping benefits deductions, employer contributions, and reimbursement accounts in one transparent ledger makes open enrollment decisions auditable months later. If you want that record in plain text you fully control — version-controlled, searchable, and ready for your accountant or auditor — Beancount.io offers plain-text accounting built for exactly that. Learn the mechanics in the docs or explore dashboards and reports in Fava.
Keep Your Benefits Bookkeeping Audit-Ready
As you finalize 2026 elections, contribution limits, and notice packets, maintaining clear financial records is what turns a compliant open enrollment into a defensible one. Beancount.io provides plain-text accounting that gives you complete transparency and control over your financial data — no black boxes, no vendor lock-in. Get started for free and see why developers and finance professionals are switching to plain-text accounting.
