In Rev. Proc. 2022-24, the IRS released the inflation adjusted amounts for 2023 relevant to Health Savings Accounts (HSAs) and high deductible health plans (HDHPs). The table below summarizes those adjustments and other applicable limits.
| 2023 | 2022 | Change | |
|
Annual HSA Contribution Limit (employer and employee) |
Self-only: $3,850 Family: $7,750 | Self-only: $3,650 Family: $7,300 | Self-only: +$200 Family: +$450 |
|
HSA catch-up contributions (age 55 or older) |
$1,000 | $1,000 | No change |
| Minimum Annual HDHP Deductible | Self-only: $1,500 Family: $3,000 | Self-only: $1,400 Family: $2,800 |
Self-only: +$100 Family: $200 |
|
Maximum Out-of-Pocket for HDHP (deductibles, co-payment & other amounts except premiums) |
Self-only: $7,500 Family: $15,000 | Self-only: $7,050 Family: $14,100 | Self-only: +$450 Family: +$900 |
The ACA’s out-of-pocket limits for in-network essential health benefits have also been announced and have increased for 2023.
| 2023 | 2022 | Change | |
| ACA Maximum Out-of-Pocket |
Self-only: $9,100 Family: $18,200 |
Self-only: $8,700 Family: $17,400 |
Self-only: +$400 Family: +$800 |
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 $9,100 (2023 plan years) or $8,700 (2022 plan years). Exceptions to the ACA’s out-of-pocket limit rule are available for certain small group plans eligible for transition relief (referred to as “Grandmothered” plans). While historically CMS has renewed the transition relief for Grandmothered plans each year, it announced in March that the transition relief will remain in effect until it announces that all such coverage must come into compliance with the specified requirements.
As employers prepare for the 2023 plan year, they should keep in mind the following rules and ensure that any plan materials and participant communications reflect the new limits:
Legal Counsel at Marathas Barrow Weatherhead Lent, LLP
About the Authors. This alert was prepared for Generous Benefits by Marathas Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act. Contact Peter Marathas or Stacy Barrow at pmarathas@marbarlaw.com or sbarrow@marbarlaw.com
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