Overview
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 2025, 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.
Out-of-Pocket Limits
The table below shows final changes to the out-of-pocket maximum dollar limits for non-grandfathered health plan years beginning January 1, 2025, as well as the changes in out-of-pocket limits from 2022 to 2024. (Final regulations for 2025 from the Department of Health and Human Services available here.) Note that the 2025 amounts represent a decrease of 2.6% from the 2024 maximums.
HDHP Limits
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 2025, as well as the limit changes from 2022 through 2024. (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 2025, the individual deductible must be at least $3,300 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 2025, the ACA limit for self-only coverage will be $900 more than that for HDHPs and $1,800 more for family coverage.
Please contact your MedCost Account Manager if you have any questions.