Preparing your health plan for 2027 open enrollment has lots of moving parts. While every health plan is a little different, here’s a basic checklist designed to cover most of the key steps most employers will want to consider to ready their employer-sponsored group health plan for their 2027 plan year enrollment.

1. Governance and Project Management

• Designate the plan fiduciary or responsible committee that will approve plan design, vendors, costs, communications, and enrollment procedures.
• Establish a written project calendar identifying responsible parties and deadlines.
• Confirm the plan year, open-enrollment dates, effective date, payroll cutoff, carrier deadlines, and employee correction period.
• Document all fiduciary decisions, supporting data, vendor recommendations, and committee approvals.
• Identify all plans included in enrollment:
  • Medical
  • Prescription drug
  • Dental
  • Vision
  • Health FSA
  • Dependent-care FSA
  • HSA
  • HRA
  • Accident, critical-illness, hospital-indemnity, or other voluntary benefits
  • Wellness program
  • Employee assistance program
• Determine which plans are ERISA plans, excepted benefits, HIPAA-covered plans, cafeteria-plan benefits, or COBRA-covered benefits.
• Confirm whether the employer is an ACA applicable large employer and, if so, coordinate enrollment with Forms 1094-C and 1095-C reporting.

ERISA fiduciaries must follow the plan documents, act prudently, defray reasonable expenses, and monitor service providers. DOL fiduciary guidance

2. Plan Design and Financial Review

• Review and modify vendor contracts, plan documents and plan communications to verify they are legally compliant and properly and consistently reflect plan sponsor’s expectations about fiduciary appointments and allocations, legal compliance, accountability and other critical information and terms.
• Review current utilization, claims, large claims, specialty-drug costs, stop-loss experience, projected trend, and pending and expected claims.
• Audit year-to-date in-network and out-of-network claims for timeliness and accuracy of processing and payment, compliance with ERISA and ACA claims and appeals procedural and notification requirements; in-network claims administration in compliance with provider contracts and applicable prompt payment rules; and out-of-network claims for reference based pricing or other budgeted projected cost versus actual expenditures including actual and projected liability arising under the No Surprises Act
• Evaluate renewal proposals and competing carrier, TPA, PBM, network, pharmacy, and stop-loss alternatives.
• Confirm:
  • Fiduciary, vendor and their staff meet ERISA prudent selection, qualification to serve, bonding, prohibited transaction and other requirements.
  • Reasonableness and prudence of vendor compensation
  • Employee and employer contributions
  • Deductibles
  • Copayments and coinsurance
  • Out-of-pocket maximums
  • Prescription-drug tiers and formularies
  • Prior-authorization requirements
  • Provider and pharmacy networks, including contractual and prompt pay liability, potential increases in out-of-network costs and liabilities potentially arising from increased No Surprises Act out of network claims
  • Mental-health and substance-use-disorder coverage
  • Fertility, gender-affirming, obesity, and specialty-drug coverage
  • Telehealth and virtual-care benefits
  • Compliance and defensibility of claims and appeals processes taking into account ERISA fiduciary responsibility, claims and appeals, and notice; ACA independent medical review and notice; prompt pay, No Surprises Act and other mandates
  • Adequacy of cybersecurity under HIPAA and ERISA fiduciary responsibility rules.
• Test plan design and administration for Mental Health Parity and Addiction Equity Act compliance.
• Review the written comparative analysis for nonquantitative treatment limitations.
• Verify compliance with the No Surprises Act, including emergency services, air ambulance claims, continuity of care, provider directories, external review, and independent dispute-resolution provisions.
• Assess reliability of reference based pricing or other out-of-network cost models against actual and projected out-of-network No Surprises Act pricing
• Confirm ACA preventive-care coverage and applicable religious or moral exemptions.
• For applicable large employers, test affordability under each intended ACA safe harbor and verify that the plan provides minimum value. The IRS generally treats a plan as providing minimum value when it covers at least 60% of expected allowed benefit costs and substantially covers inpatient hospital and physician services. IRS affordability and minimum-value guidance
• Reconcile the plan’s family-definition and dependent-eligibility provisions across the plan document, SPD, carrier contracts, payroll system, and enrollment platform.

3. 2027 HSA-Compatible HDHP Review

For any HSA-qualified HDHP, confirm that the plan and enrollment system use the 2027 limits:

2027 requirement	Self-only	Family
HSA contribution limit	$4,500	$9,000
Minimum HDHP deductible	$1,750	$3,500
Maximum HDHP out-of-pocket amount	$8,700	$17,400

• Include the additional $1,000 HSA catch-up contribution available to an eligible individual age 55 or older.
• Coordinate employer and employee HSA contributions so the combined amount does not exceed the applicable limit.
• Confirm that no disqualifying first-dollar medical coverage is offered through an FSA, HRA, or other arrangement.
• Properly coordinate embedded family deductibles and out-of-pocket limits.
• Review telehealth, direct-primary-care, and other HSA eligibility provisions under current law.
• Verify payroll coding, employer contributions, trustee information, and employee HSA-election instructions.

The 2027 amounts are established in IRS Revenue Procedure 2026-24. IRS Internal Revenue Bulletin 2026-25

4. Plan Documents and Contracts

• Ensure plan documents, summary plan descriptions and communications, and vendor contracts name party responsible for performing each task and optimally designates that party as the named fiduciary responsible for performing that task.
• Update and reconcile:
  • Formal plan document
  • Summary Plan Description
  • Summary of Material Modifications
  • Summary of Benefits and Coverage
  • Wrap-plan document
  • Section 125 cafeteria-plan document
  • Insurance policies and certificates
  • Administrative-services agreements
  • PBM agreement
  • Stop-loss policy
  • Network and utilization-review arrangements
  • Claims and Appeals, including special Independent Medical Review, Mental Health Parity, Coordination of Benefits and Subrogation, No Surprises Act and other key procedures
  • Business associate agreements
• Confirm that discretionary authority and claims-administration responsibilities are properly delegated.
• Verify that exclusions, medical-necessity standards, prior-authorization requirements, appeal rights, and external-review procedures are consistent across all controlling documents.
• Confirm that vendor contracts address:
  • Not Disqualified From Serving Under ERISA
  • Bonded In Accordance With ERISA
  • Prudence of Selection Documented
  • Performance standards
  • Fiduciary status and delegated duties
  • Procedural and Operational Compliance with Plan Documents, Legal Mandates, Stop-Los and Other Reinsurance
  • Data ownership and access
  • Cybersecurity and breach notification
  • HIPAA compliance
  • Prudence, reasonableness and defensibility of compensation
  • Compensation and fee disclosures
  • Rebates and other remuneration
  • Audit rights
  • Indemnification
  • Claims and record retention
  • Transition assistance
  • Accountability for vendor performance with plan document, ERISA, ACA and other applicable requirements
  • Errors and Omissions and Cyber Liability Insurance Adequacy
• Ensure that plan amendments are formally adopted before or as of their effective dates.
• Retain RFP and other vendor investigation and selection, signed amendments, resolutions, contracts, notices, and final enrollment materials.

The SPD is the principal document for communicating how an ERISA plan operates, and an SMM generally must disclose material amendments within the applicable ERISA deadline. DOL Reporting and Disclosure Guide

5. Required Notices and Enrollment Materials

Determine which notices apply rather than automatically placing every notice in one undifferentiated packet.

• Current Summary of Benefits and Coverage for each medical option.
• Uniform glossary or instructions for obtaining it.
• Summary Plan Description or Summary of Material Modifications.
• Medicare Part D creditable or noncreditable coverage notice.
• CHIP premium-assistance notice.
• Women’s Health and Cancer Rights Act notice.
• HIPAA special-enrollment notice.
• HIPAA Notice of Privacy Practices or notice of availability, as applicable.
• Wellness-program notices, including HIPAA and ADA notices where applicable.
• Grandfathered-plan notice, if applicable.
• Patient-protection notice concerning choice of primary-care provider, if applicable.
• COBRA general notice for individuals who have not previously received it.
• Marketplace notice for newly hired employees, if appropriate to the enrollment process.
• Qualified small-employer HRA, individual-coverage HRA, or excepted-benefit HRA notices, if applicable.
• Fixed-indemnity excepted-benefit notice in applicable enrollment and reenrollment materials.
• State-required continuation, insurance, privacy, infertility, or coverage notices.
• Notices required under a collective-bargaining agreement.

An SBC ordinarily must be provided with enrollment materials or by the applicable renewal deadline; special rules apply to automatic renewals and changes occurring after the SBC is distributed. CMS SBC guidance

The Part D creditable-coverage notice generally must be provided to Medicare-eligible individuals before October 15 each year and at other required times. The plan sponsor’s online disclosure to CMS is generally due within 60 days after the beginning of the plan year. CMS creditable-coverage guidance

6. Employee Communications

• Prepare a plain-language enrollment guide.
• Clearly identify:
  • What is changing
  • What is not changing
  • Premium contributions
  • Deductibles and out-of-pocket exposure
  • Network changes
  • Prescription-drug changes
  • Required employee actions
  • Default coverage if no election is submitted
  • Enrollment deadline
  • Effective date
  • Available assistance
• Explain that annual FSA elections generally do not carry forward automatically.
• Explain HSA eligibility and contribution limitations.
• Tell employees how to verify providers, facilities, pharmacies, drugs, and prior authorizations.
• Explain dependent-eligibility requirements and required supporting documentation.
• Provide instructions for adding or removing dependents.
• Explain consequences of waiving coverage.
• Describe midyear election-change and HIPAA special-enrollment rights.
• Provide translated materials and disability-accessible formats when needed.
• Identify a knowledgeable contact for enrollment questions.
• Require vendors and call-center representatives to use approved and consistent scripts.
• Review communications for misleading comparisons or statements that conflict with the plan documents.

7. Enrollment-System and Payroll Testing

• Configure each plan option, coverage tier, eligibility class, waiting period, and contribution amount.
• Test employee, spouse, domestic-partner, and dependent eligibility.
• Verify age-out and disabled-dependent rules.
• Test affordability calculations and applicable measurement/stability-period coding.
• Confirm that evidence-of-insurability requirements apply only where appropriate.
• Test passive-enrollment defaults.
• Test FSA and HSA maximums.
• Test employer HSA and HRA contributions.
• Verify payroll deductions for each pay frequency.
• Confirm pretax versus after-tax deduction coding.
• Test imputed income for domestic-partner or other non-tax-dependent coverage.
• Confirm COBRA rates and administrative fees.
• Confirm that enrollment vendors transmit only the minimum necessary PHI.
• Perform end-to-end testing among the enrollment system, payroll, carrier, TPA, PBM, HSA trustee, FSA administrator, COBRA administrator, and stop-loss carrier.
• Retain screenshots and test results demonstrating approval of the final configuration.

8. During Open Enrollment

• Open the system only after final configuration approval.
• Monitor rejected transactions, incomplete elections, and system errors daily.
• Track employees who have not completed required elections.
• Send deadline reminders sufficiently before enrollment closes.
• Provide nondiscriminatory assistance to employees who lack online access.
• Document outages and extend deadlines when necessary to prevent prejudice.
• Require affirmative confirmation of:
  • Coverage elections
  • Dependents
  • Tobacco or wellness attestations
  • FSA elections
  • HSA elections
  • Beneficiary information, when applicable
• Provide employees with an election confirmation.
• Maintain a controlled procedure for correcting employee or system errors.

9. Post-Enrollment Reconciliation

• Reconcile employee elections against carrier and vendor enrollment files.
• Reconcile payroll deductions against elections before the first payroll.
• Confirm receipt and acceptance of every eligibility file.
• Investigate all file errors, rejected records, and missing dependents.
• Verify identification-card production and delivery.
• Confirm that continuing-treatment authorizations and continuity-of-care rights are protected during vendor or network changes.
• Provide updated documents and notices by their required deadlines.
• Submit the Medicare Part D disclosure to CMS within the applicable deadline.
• Update COBRA rates and notify the COBRA administrator.
• Preserve election records, confirmations, waivers, notices, mailing evidence, electronic-delivery consents, and system logs.
• Schedule a 30- to 60-day post-enrollment audit.
• Correct payroll, eligibility, or vendor discrepancies promptly and document the correction.

10. Special Situations Requiring Additional Review

• No Surprises Act and other out-of-network design and compliance
• Plan termination or replacement
• Change in insurer, TPA, PBM, network, or stop-loss carrier
• Material reduction in covered services or benefits
• Grandfathered plan
• Church or governmental plan
• Collectively bargained plan
• Multiemployer plan
• Multiple employer welfare arrangement
• Level-funded or self-funded arrangement
• Individual-coverage HRA or QSEHRA
• Retiree-only coverage
• Health-contingent wellness program
• Reference-based pricing
• Direct contracting
• Coverage of employees in multiple states
• Acquisition, merger, divestiture, or controlled-group change
• Plan eligibility involving variable-hour, seasonal, temporary, or leased employees

Completing this or other similar checklists may help minimize the exposure of the health plan, its sponsor, fiduciaries and their staff to unexpected costs, liabilities and other headaches. While not necessarily exhaustive, this is a general compliance checklist that covers most of the key responsibilities employers and health plan fiduciaries should consider when preparing their health plans for 2027 annual enrollment. Of course, every plan sponsor and fiduciary should verify that the checklist is tailored to the plan type, administrative type, specific legal mandates, plan design, funding arrangement, workforce, effective date and other requirements as well as new regulations, litigation and claims experienced, and audit and enforcement developments.

Documenting these efforts also is important, as capturing and preserving this documentation could help employers or plan fiduciaries to demonstrate their compliance efforts as well as document evidence that could be used to help demonstrate the prudence of the efforts of plan fiduciaries in the event of future litigation or audits.

Want more helpful updates about these and other human resources and employee benefit concerns? Stay tuned for more updates by following this blog.

For Help or More Information

The author of this update, Cynthia Marcotte Stamer is an attorney Board Certified in Labor and Employment Law by the Texas Board of Legal Specialization with decades of experience advising and assisting health industry and other employers to design, audit, and defend their employment and other risk management and compliance practices, including conducting audits and investigations, designing and updating compliance and risk management programs, responding to government investigations, conducting transaction, governance, and other due diligence, and assisting with other legal and operational compliance and risk management and legislative and regulatory affairs. She is available to assist your organization in assessing the impact of these developments and navigating the compliance and strategic steps that follow. For more information about these concerns or Ms. Stamer, contact Ms. Stamer via e-mail or via telephone at (214) 452 -8297.

About the Author

Cynthia Marcotte Stamer is an American College of Employee Benefits Counsel and a Martindale-Hubble “AV-Preeminent” (Top 1%) attorney and advisor board certified in labor and employment law by the Texas Board of Legal Specialization peer peer celebrated as “Top Rated Lawyer” and “LEGAL LEADER™ “Top Rated Lawyer” and “Best Lawyer” for her work in ERISA & Employee Benefits Law, Health Care Law, Labor and Employment Law, and Business and Commercial Law.

Nationally recognized for her decades of leading-edge workforce, health and other employee benefits and insurance, compensation, regulatory affairs and compliance, and other management work, public policy leadership and advocacy, coaching, teachings, and publications, she is the publisher of Solutions Law Press, Inc.® practitioner-focused compliance publications for employers, plan sponsors, HR professionals, health care, insurance, technology and data industry leaders, and legal counsel and risk management advisors.

Along with these activities, Ms. Stamer also has earned national recognition for her authorship of thousands of highly regarded works, presentations as a knowledgeable speaker, testimony and other input of regulators and legislators, and media interviews on health and other benefits, human resources and other workforce, health care, insurance, data privacy and security and other related concerns. 

For more information about Ms. Stamer, engaging her services or to speak, her work, credentials, experience and involvements, or other matters, see the About the Author page, her website at www.cynthiastamer.com, or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.