2016 Health Savings Account (HSA) Guidelines

Earlier this summer (2016) the IRS released its annual guidance affecting Health Savings Accounts (HSA), and associated qualified high deductible health plans (QHDHP).  Interestingly, for the first time since rules were relaxed to allow contribution amounts to be higher than a percentage of the deductible (remember those days?), the IRS chose to keep the maximum HSA contribution limit for individual coverage static; but increased the HSA family coverage limit.  Despite keeping the maximum allowable HSA contribution amount unchanged for those having individual only coverage, the IRS did, however, increase the maximum out of pocket limit associated with the required/accompanying QHDHP for individuals (in addition to families).
Here's an overview of the changes affecting both HSAs and QHDHP's, starting in 2016...

Health Savings Account (HSA) contribution limits:

• Individual Coverage: $3,350 (no change from 2015)
• Family Coverage: $6,750 (an increase of $100 from 2015)
• As a reminder, so called family coverage is defined as an individual plus one or more dependents.

Qualified High Deductible Health Plan (QHDHP) out of pocket limits:

• Individual Coverage*
• Deductible must be at least $1,300 and no greater than $2,600 annually.
• Out of Pocket limit (deductible plus additional requirements such as post deductible copays and coinsurance) may not exceed $6,550 annually (which is a $100 increase from 2015).
• Family Coverage
• Deductible must be at least $2,600 annually
• Out of Pocket limit (deductible plus additional requirements such as post deductible copays and coinsurance) may not exceed $13,100 annually (which is a $200 increase from 2015).

* IMPORTANT: Recent guidance issued by the trilogy of ACA compliance and enforcement -Departments of Labor/Treasury/Health & Human Services – affects QHDHPs (both inforce and newly established) starting in 2016.  The guidance indicates that the annually published ACA out of pocket maximums affect so called “aggregate” or "non-embedded" family deductibles that are part of many QHDHP’s.  (Note: QHDHP’s that utilize embedded family deductibles and grandfathered plans would not be impacted by the change.)  

This means that QHDHPs having a non-embedded or aggregate deductible for family coverage will be required to limit the deductible exposure facing any one family member to the ACA individual maximum out of pocket limit for 2016, which is $6,850.

For more information on this guidance and the impact on affected plans, go to -https://www.smstevensandassociates.com/ResourceLibrary/tabid/192/Default.aspx

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