Open Enrollment 2027: What Employers Need to Do Right Now

August is the most important month on the benefits calendar, not November. By the time open enrollment opens, employers who haven’t done their groundwork are already behind. Here’s your 2027 preparation checklist.

Why August Is Your Real Open Enrollment Deadline

Most employers think open enrollment starts in October or November. Technically, that’s true. But the employers who run a smooth, compliant, cost-effective open enrollment season are the ones who started their preparation in August, or earlier.

With 2027 plan year changes already taking shape, rising out-of-pocket maximums, and ACA employer mandate penalties continuing to climb, the cost of waiting is measurable. Here’s what you need to be doing right now.

Step 1: Audit Your Current Workforce Headcount

Before you can select or renew benefit plans, you need a clear picture of your workforce composition. For Applicable Large Employers (ALEs), those with 50 or more full-time equivalent employees, this headcount directly determines your ACA compliance obligations.

In August, pull reports on:

•       Full-time employees (30+ hours per week average)
•       Part-time and variable-hour employees whose FTE hours may affect your ALE status
•       Seasonal employees and their hours over the measurement period
•       Any workforce changes, new hires, terminations, or classification changes, since your last reporting cycle

If your headcount is near the 50-FTE threshold, a miscalculation here can trigger or eliminate your ACA mandate obligations for the entire plan year. Don’t estimate, run the numbers.

Step 2: Review ACA Affordability for 2027

The ACA’s affordability threshold changes annually. For 2026, the threshold sits at 9.96% of an employee’s household income for self-only coverage. While 2027 figures won’t be officially published until later in the year, employers should begin modeling coverage scenarios now using the current threshold as a baseline.

Why it matters: If your employee premium contributions exceed the affordability threshold, full-time employees can qualify for marketplace subsidies, and you’ll owe a penalty of up to $4,350 per employee who does. That exposure compounds fast in large workforces.

 Use this period to review your current premium structure, especially if you’ve had wage increases across the workforce. Higher wages can actually push previously affordable contributions back over the threshold.

Step 3: Evaluate Whether Your Plan Still Fits Your Workforce

August is the right time to evaluate whether your current benefit structure, MEC plan, Restricted Medical, voluntary add-ons, still aligns with your workforce’s needs and your organization’s budget.

Questions to answer now:

•       Has your workforce composition changed significantly? (Rapid growth, new locations, industry mix shifts)
•       Are employees actually using the benefits you’re paying for? Low utilization often signals a plan that doesn’t meet real needs.
•       Do you have coverage gaps in dental, vision, or supplemental plans that are affecting retention or recruitment?
•       Are your brokers and TPA providing the administrative support you need, or are you carrying too much internal burden?

If any of these questions surface a mismatch, August gives you time to make a change before open enrollment begins, not scramble during it.

Step 4: Get Your Communications Strategy Ready

Employee confusion during open enrollment is one of the leading causes of missed enrollments, benefits disputes, and HR headaches. Preparation means having communications drafted, reviewed, and ready to deploy before the window opens.

Your August communications checklist should include:

•       A summary of benefits changes (even if minimal, employees want confirmation of stability)
•       Clear enrollment deadlines and instructions for your enrollment platform
•       FAQ document covering the top questions your HR team fielded last year
•       Reminder cadence: at least three touchpoints from enrollment open through deadline

Pro tip: Review last year’s enrollment errors and late submissions. Those patterns tell you exactly where communication broke down, and where to focus your 2027 messaging.

Step 5: Confirm Your 1094/1095 Reporting Readiness

ACA reporting for the 2027 plan year begins the following January, but the data that feeds those forms is being created right now. Employers who wait until Q1 to organize their eligibility data, offer documentation, and coverage records face a significantly harder filing process, and greater audit exposure.

In August, confirm with your TPA or benefits administrator that:

•       Eligibility tracking is running cleanly and capturing all required data points
•       Offer-of-coverage records are being documented in real time
•       Any mid-year workforce events (new hires, terminations, classification changes) are reflected accurately in your system

The Best Open Enrollment Is the One You Prepared For

Open enrollment isn’t a single event, it’s the result of months of planning. Employers who treat August as the starting line consistently report smoother processes, fewer compliance issues, and better employee participation than those who begin when the enrollment window opens.

SBMA works with employer groups of all sizes to ensure their benefits strategy is ready well before open enrollment season. Whether you need a plan review, affordability modeling, or full-service enrollment support, our team is here to make the process simpler.

Ready to get ahead of open enrollment? Contact SBMA today to review your 2027 benefits strategy. Our team can run your affordability analysis, review your workforce headcount, and help you select or renew plans before the season rush begins.