The IRS has released the inflation-adjusted contribution and related amounts for health savings accounts (HSAs) and HSA-compatible high-deductible health plans (HDHPs) for 2023. The limits are set forth below.
2023 HSA limits
Annual HSA contribution maximum
$3,850 for single coverage ($200 increase from $3,650)
$7,750 for family coverage ($450 increase from $7,300)
Annual catch-up contribution maximum
$1,000 (for HSA-eligible individuals age 55 or older) (no change)
HDHP minimum deductible
$1,500 for single coverage ($100 increase from $1,400)
$3,000 for family coverage ($200 increase from $2,800)
HDHP out-of-pocket maximum
$7,500 for single coverage ($450 increase from $7,050)
$15,000 for family coverage ($900 increase from $14,100)
The HSA rules under the federal tax code limit the in-network out-of-pocket (OOP) expenses an insured may incur under an HSA-compatible HDHP. These limits are different from the ACA-imposed OOP limits applicable to non-grandfathered health plans. The ACA-imposed OOP maximums apply to in-network essential health benefits while the HDHP OOP limits apply to all HDHPs, grandfathered or non-grandfathered, and must take into account all in-network OOP expenses without regard to whether the expenses are for essential health benefits.
The ACA OOP limits for 2023 are $9,100 for self-only coverage and $18,200 for family coverage.
Lockton comment: From a practical perspective, most plans will opt to apply the lower of the OOP maximum requirements, in this case the OOP maximum applied to HDHPs, to avoid having to determine what expenses must be rolled up against which applicable OOP limit.
Note that non-grandfathered plans are required to embed the ACA individual OOP limit for everyone enrolled in coverage other than self-only coverage. This means each enrollee under, say, family coverage must have his or her own individual OOP limit on essential health benefits that can be no higher than the ACA’s maximum OOP limit for self-only coverage.
Not legal advice: Nothing in this alert should be construed as legal advice. Lockton may not be considered your legal counsel, and communications with Lockton's Compliance Services group are not privileged under the attorney-client privilege.