Massachusetts 2027 MCC Limits: Deductibles and Out-of-Pocket Maximums

The Massachusetts Health Connector has issued Administrative Information Bulletin 01-26, providing updated guidance on the 2027 dollar limits under the state’s Minimum Creditable Coverage (MCC) rules. The bulletin explains how the Commonwealth calculates annual deductible limits and maximum out-of-pocket limits for coverage subject to 956 CMR 5.00.

These updates are important for employers, insurers, third-party administrators, and Massachusetts residents who rely on employer-sponsored health coverage to satisfy the state’s individual health insurance mandate.

Overview of Massachusetts MCC Requirements

Massachusetts has required most adult residents to maintain qualifying health coverage since the Massachusetts Health Care Reform Act took effect in 2007. Under the law, residents age 18 and older must generally have health insurance that meets Minimum Creditable Coverage standards or risk a penalty on their Massachusetts state income tax return.

MCC is primarily an individual mandate requirement, not an employer mandate. Employers are not required to offer plans that meet MCC standards. However, employees who live in Massachusetts may need employer-sponsored coverage to qualify as MCC in order to avoid state tax penalties.

For this reason, employers with Massachusetts-based employees should review plan designs each year and coordinate with insurers or administrators to confirm whether coverage satisfies MCC standards.

2027 MCC Deductible Limits

For 2027, the MCC deductible limits remain unchanged from the 2026 amounts.

The maximum annual deductible limits are:

Coverage Tier2027 MCC Deductible LimitIndividual Coverage$3,200Family Coverage$6,400

Plans with a separate prescription drug deductible must also comply with MCC limits. For 2027, a separate prescription drug deductible may not exceed:

Coverage Tier2027 Prescription Drug Deductible LimitIndividual Coverage$400Family Coverage$800

If a plan includes a separate prescription drug deductible, the overall deductible structure must still comply with the applicable MCC maximum deductible rules.

2027 MCC Out-of-Pocket Maximums

The 2027 MCC out-of-pocket maximum limits increase to reflect the applicable federal cost-sharing limits.

For 2027, the MCC maximum out-of-pocket limits are:

These out-of-pocket maximums apply to cost-sharing amounts such as deductibles, copayments, and coinsurance for covered in-network services that are subject to MCC standards.

Why These Limits Matter for Employers

Although Massachusetts employers are not directly required to offer MCC-compliant coverage, the rules can still affect employer-sponsored health plans. Employees who reside in Massachusetts often rely on their workplace health plan to meet the state’s individual mandate.

Employers sponsoring health plans that cover Massachusetts residents should confirm whether their coverage satisfies MCC requirements for the 2027 plan year. This may involve reviewing deductible levels, prescription drug deductibles, out-of-pocket maximums, and required reporting obligations.

Employers should also work with carriers, third-party administrators, or benefits advisors to determine whether Forms MA 1099-HC will be prepared and distributed to covered Massachusetts residents.

Employer Action Steps for 2027

Employers with Massachusetts resident employees should consider the following steps before the 2027 plan year begins:

  1. Review plan deductibles against the 2027 MCC limits.

  2. Confirm whether any separate prescription drug deductible complies with MCC rules.

  3. Compare the plan’s out-of-pocket maximums with the 2027 MCC thresholds.

  4. Coordinate with insurers or TPAs regarding MCC status and Form MA 1099-HC reporting.

  5. Identify any plan design changes needed for plan years beginning on or after January 1, 2027.

Effective Date

Administrative Information Bulletin 01-26 is effective immediately. The updated MCC limits that apply to employer-sponsored coverage should be incorporated for plan years beginning on or after January 1, 2027.

Employers with Massachusetts employees should review these changes early to help ensure accurate plan design, employee communications, and reporting compliance for the 2027 plan year.

Mark C