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IRS Announces 2016 HSA Contribution Limits, HDHP Minimum Deductibles, and HDHP Out-of-Pocket Maximums

Rev. Proc. 2015-30 (May 4, 2015)

Available at http://www.irs.gov/pub/irs-drop/rp-15-30.pdf

The IRS has released the 2016 cost-of-living adjustments affecting health savings accounts (HSAs) and high-deductible health plans (HDHPs). Here are the details:

  • HSA Contribution Limits. The 2016 annual HSA contribution limit for individuals with self-only HDHP coverage is $3,350 (unchanged from 2015), and the limit for individuals with family HDHP coverage is $6,750 (a $100 increase from 2015).
  • HDHP Minimum Required Deductibles. The 2016 minimum annual deductible for self-only HDHP coverage is $1,300 (unchanged from 2015) and the minimum annual deductible for family HDHP coverage is $2,600 (unchanged from 2015).
  • HDHP Out-of-Pocket Maximums. The 2016 maximum limit on out-of-pocket expenses (including items such as deductibles, copayments, and coinsurance, but not premiums) for self-only HDHP coverage is $6,550 (a $100 increase from 2015), and the limit for family HDHP coverage is $13,100 (a $200 increase from 2015).

EBIA Comment: Because the HDHP out-of-pocket maximums continue to grow faster than the HSA contribution limits, some individuals may have to pay more out-of-pocket expenses in 2016 without the benefit of using pre-tax HSA dollars. And remember that the HDHP out-of-pocket maximum limit no longer aligns with health care reform’s overall cost-sharing limit (applicable to non-grandfathered, nonexcepted group health plans, including HDHPs) because the limits are subject to different cost-of-living adjustments—effectively subjecting HDHPs to two sets of limits on out-of-pocket expenses. (See our article on the 2016 health care reform cost-sharing limits, and our article on recent FAQ guidance explaining how the individual cost-sharing limit applies in the context of family coverage.) For more information on HSA- and HDHP-related limits and deductibles, see EBIA’s Consumer-Driven Health Care manual at Sections X (“HSAs: Required HDHP Coverage“) and XII (“HSAs: Contributions“). See also EBIA’s Cafeteria Plans manual at Section XVI.K (“Special Considerations for HSAs Offered Through Cafeteria Plans“). For more on the relationship between the HDHP out-of-pocket limit and health care reform’s overall cost-sharing limit, see EBIA’s Health Care Reform manual at Section IX.B.3 (“Dollar Amount of Overall Cost-Sharing Limits”).

Contributing Editors: EBIA Staff.

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