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.
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.
Keep reading.
HealthCare.gov premiums rise again in 2027
What the 2027 marketplace increases mean for an employer plan. Back to the marketplace page.
Keep reading on 2027 marketplace premiums.
Where these figures and rules come from.
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.
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