ACA Affordability

The ACA affordability test does not use marketplace prices.

Rising HealthCare.gov premiums do not change how an employer’s coverage is tested for affordability. The test looks at what the employee pays for your lowest-cost self-only plan that provides minimum value, measured against an income percentage the IRS publishes each year.

What marketplace increases do change is how many employees look at their own eligibility for a premium tax credit, which is where employer exposure comes from. Send us your renewal and we will give you a second opinion in writing.

What to know

Three things the test does and does not do.

What it measures

Affordability for an applicable large employer, meaning one with 50 or more full-time equivalent employees, is measured on the employee’s share of the premium for the lowest-cost self-only coverage (26 CFR §54.4980H-5(e)). Confirm the IRS percentage for 2027 in its annual revenue procedure; it changes each year.

Why more claims may follow

If an employee’s offer is not affordable or lacks minimum value and the employee receives a premium tax credit, the employer can face a payment under IRC §4980H(b). Higher marketplace prices make more employees check.

Safe harbors and reporting

The IRS offers safe harbors that let employers test affordability using W-2 wages, rate of pay or the federal poverty line, and the result is reported on Form 1095-C. See what Form 1095-C reports. For the 2027 numbers, see the 2027 affordability guide.

Related

Keep reading.

The hub

HealthCare.gov premiums rise again in 2027

What the 2027 marketplace increases mean for an employer plan. Back to the marketplace page.

Related

Next step

Read what Form 1095-C reports.

Sources

Where these figures and rules come from.

Sources

Figures and rules

Premium tax credit eligibility: IRC §36B(c)(2)(C). Employer shared responsibility payments and the 50 full-time-equivalent threshold: IRC §4980H. Affordability measurement: 26 CFR §54.4980H-5(e). KFF and The Hill: KFF estimates about 13% for HealthCare.gov in 2027, as reported by The Hill on October 31, 2026; KFF’s review of insurer filings found a median proposed increase of 15% (KFF, How Much and Why ACA Marketplace Premiums Are Going Up in 2027). This page is general information, not legal or tax advice.

Let’s Get to Work

Send us your renewal.

Four documents — the renewal letter, the plan summary, the contribution split by tier and enrolled counts by tier. We’ll come back with a competitive read, where we see opportunity, and the five questions we’d put to your carrier.

Start the Review248.370.8853

CFH Insurance Consultants

An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.

Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →

Michigan41000 Woodward Avenue, Suite 350 East
Bloomfield Hills, MI 48304
248.370.8853
Colorado13540 Northgate Estates, Suite 100
Colorado Springs, CO 80921
719.425.2649
Texas16365 Park Ten Place, Suite 182
Houston, TX 77084
281.404.5670

Book a 30-minute call