As plan sponsors begin to evaluate plan design changes for the coming year, MedCost wants to ensure awareness of the amounts for ACA out-of-pocket limits, HDHP minimum deductibles, HDHP out-of-pocket maximums, and inflation adjusted HSA contribution limits for 2024, as determined by the Department of Health and Human Services and the IRS. Additionally, it is important to note that the referenced changes below are effective upon a plan’s prospective renewal date. For more information, see Q&A-86 in IRS Notice 2004-50.
The table below shows final increases to the out-of-pocket maximum dollar limits for non-grandfathered health plan years beginning January 1, 2024, as well as the changes in out-of-pocket limits from 2021 to 2023. (Final regulations for 2024 from the Department of Health and Human Services available here.) Note that the 2024 amounts represent an increase of 3.8% from the 2023 maximums.
The table below shows the inflation-adjusted contribution, deductible, and out-of-pocket dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for calendar year 2024, as well as the limit changes from 2021 through 2023. (For more information, see IRS Revenue Procedure 2023-23.)
If the HDHP has an embedded deductible, the individual deductible must be equal to or more than the IRS minimum family deductible. For example, for plan years beginning in 2024, the individual deductible must be at least $3,200 to maintain qualifying HSA/HDHP status.
Interaction Between Two Out-of-Pocket Limits
Employers who sponsor health plans that must comply with both the ACA and IRS out-of-pocket limits should note that the ACA limits continue to be higher than the IRS amounts. In 2024, the ACA limit for self-only coverage will be $1,400 more than that for HDHPs and $2,800 more for family coverage.
Please contact your MedCost Account Manager if you have any questions.