Non-calendar plan years: which percentage applies?

The 10.22% applies to plan years that begin in 2027. A non-calendar plan uses the percentage in effect on the day its plan year starts.

For a plan that renews before 2027, that is still the 2026 figure of 9.96%. Send us your renewal and we will give you a second opinion in writing.

What to know

Three things to check.

The start date decides

A plan year that began in 2026 uses the 2026 percentage until it renews, even if it runs into 2027. A plan that begins in 2027 uses 10.22% for its whole plan year.

Mixed calendars

If you offer more than one plan with different renewal dates, test each against the percentage that applies on its own start date.

Poverty-line safe harbor

The poverty-line limit also depends on the plan year start, because it uses the guideline in effect six months earlier. Do not reuse a calendar-year number for a different renewal date.

Keep reading.

The guide

The 2027 ACA Affordability Percentage: Employer Guide

What the IRS changed for 2027 and what to check before open enrollment. Back to the guide.

Next step

Read the poverty-line safe harbor.

Sources

Where these figures and rules come from.

Sources

Figures and rules

IRS Rev. Proc. 2026-26 (2027 affordability percentage of 10.22%, up from 9.96% for 2026) and Rev. Proc. 2026-22 (2027 employer shared responsibility payment amounts). 26 CFR §54.4980H-5(e)(2). 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 Review 248.370.8853

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