IRS Releases 2024 HSA Contribution Limits and HDHP Deductible and Out-of-Pocket Limits

In Rev. Proc. 2023-23, the IRS released the inflation-adjusted amounts for 2024 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs). The table below summarizes those adjustments and other applicable limits.

Annual HSA Contribution Limit (employer and employee).

The 2024 Self-only maximum is $4,150 an increase of $300 from 2023

The 2024 Family maximum is $8,300 an increase of $550 from 2023

HSA catch-up contributions for employees age 55 or older remains unchanged with a maximum $1,000 for 2024

Minimum Annual HDHP Deductible

The Self-only minimum deductible for 2024 is $1,600 an increase of $100 from 2023.

The Family minimum deductible increased to $3,200 an increase of $200 from 2023.

Maximum Out-of-Pocket for HDHP (deductibles, co-payment & other amounts except premiums)

The Self-only MOOP increased to $8,050 an increase of $550 from 2023

The Family MOOP increased to $16,100 an increase of $1,100 from 2023

Out-of-Pocket Limits Applicable to Non-Grandfathered Plans

The ACA’s out-of-pocket limits for in-network essential health benefits have also been announced and have increased for 2024.

ACA Maximum Out-of-Pocket

The Self-only ACA OOP Maximum increased to $9,450 an increase of $350 from 2023

The Family ACA OOP Maximum increased to $18,900 an increase of $700 from 2023

Note that all non-grandfathered group health plans must contain an embedded individual out-of-pocket limit within family coverage if the family out-of-pocket limit is above $9,450 (2024 plan years) or $9,100 (2023 plan years). Exceptions to the ACA’s out-of-pocket limit rule have been available for certain non-grandfathered small group plans eligible for transition relief (referred to as “Grandmothered” plans) since policy years renewed on or after January 1, 2014.  Each year, CMS has extended this transition relief for any Grandmothered plans that have been continually renewed since on or after January 1, 2014.  However, in its March 23, 2022 Insurance Standards Bulletin, CMS announced that the limited nonenforcement policy will remain in effect until CMS announces that such coverage must come into compliance with relevant requirements.   Thus, we will no longer see annual transition relief announced.

Next Steps for Employers

As employers prepare for the 2024 plan year, they should keep in mind the following rules and ensure that any plan materials and participant communications reflect the new limits:

All non-grandfathered plans (whether HDHP or non-HDHP) must cap out-of-pocket spending at $9,450 for any covered person. A family plan with an out-of-pocket maximum in excess of $9,450 can satisfy this rule by embedding an individual out-of-pocket maximum in the plan that is no higher than $9,450. This means that for the 2024 plan year, an HDHP subject to the ACA out-of-pocket limit rules may have a $8,050 (self-only) / $18,900 (family) out-of-pocket limit (and be HSA-compliant) so long as there is an embedded individual out-of-pocket limit in the family tier no greater than $9,450 (so that it is also ACA-compliant).

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