2016 HSA Limits & New Out Of Pocket Rule

June 29, 2015

On May 5, 2015, the IRS published the 2016 limits for HSA contributions and qualified High Deductible Health Plans (HDHP):

Self-Only Coverage

Family Coverage

2015

2016

2015

2016

HSA Maximum Contribution:

$3,350

$3,350*

$6,650

$6,750

HDHP Minimum Deductible:

$1,300

$1,300*

$2,600

$2,600*

HDHP Maximum Out Of Pocket:

$6,450

$6,550

$12,900

$13,100

ACA Maximum Out Of Pocket:

$6,600

$6,850

$13,200

$13,700

*no change

Starting in 2016, the ACA Maximum Out Of Pocket (OOP) limits will also affect HDHP Maximum OOP limits. The Department of Health and Human Services (HHS) announced on February 27, 2015 that the self-only ACA Maximum OOP limit of $6,850 will apply to all individuals, even if the individual has family coverage, including HDHP coverage.

Normally, under HDHP family level coverage any covered family member could incur up to the Maximum Family OOP on their own before benefits are paid at 100%. The Maximum applies to the family as a whole regardless of whether the claims are all incurred by one member or are spread among the members. Under the new ACA rule, regardless of the family Maximum OOP, each covered family member cannot be required to pay more than the ACA Maximum OOP limit of $6,850.

For example:

    • If the HDHP has a Maximum OOP self-only $3,000 / family $6,000, then the limits apply as usual up to $6,000 for the family. The HDHP family Maximum ($6,000) is lower than the ACA self-only Maximum ($6,850), so the plan is not affected by the new rule.
  • If the HDHP has a Maximum OOP self-only $5,000 / family $10,000, then the new ACA self-only Maximum OOP of $6,850 applies. If any covered family member reaches $6,850 in claims, then any further claims for that individual must be paid 100% by the plan while the rest of the family continues to incur claims until the full family level HDHP Maximum OOP has been reached.

Note: If the HDHP family Maximum OOP is $6,850 or lower, then the plan will continue to operate as it always has with no changes. Only plans with family limits higher than $6,850 will have to navigate this duality of Maximums.