Blog 5/22/2020

IRS; HHS Announce New Guidance for Health Plans

As expected, the IRS has released the HSA contribution limits for 2021 along with deductible and OOP parameters for high deductible plans:

  • The HSA contribution limits for 2021 will be $3,600 for self-only coverage and $7,200 for family coverage, an increase of $50 and $100 from 2020 levels, respectively.
  • With respect to high deductible plans, the minimum deductible requirement for 2021 remains at $1,400 for self-only coverage and $2,800 for family coverage. The annual out-of-pocket expenses may not exceed $7,000 for self-only coverage or $14,000 for family coverage in 2021 (up $100 and $200, respectively).
  • The catch-up contribution limit for employees age 55 or older remains at $1,000.

For details, see: https://www.irs.gov/pub/irs-drop/rp-20-32.pdf

In addition, last week HHS announced:

  • The 2021 out-of-pocket limit for non-grandfathered group health plans will be increased to $8,550 for self-only coverage and $17,100 for other than self-only coverage (compared to $8,150 and $16,300 for 2020). These limits apply to all OOP costs for in-network essential health benefits.
  • Self-funded group health plans may, but are not required to, exclude the value of drug manufacturer’s coupons from amounts counted towards the plan’s deductible or out-of-pocket limit (I’ve seen a few of my clients address this topic specifically in their SPDs recently). Previously, these expenses could be excluded only if the drug had a generic equivalent available. (Fully insured plans should note that some states require insurers to count coupons and copay assistance towards a plan’s deductible and OOP limit.)

    If an HSA-eligible high deductible plan wishes to exclude coupons and copay cards from deductibles and OOP limits, the plan must adopt a copay accumulator program.

For details on the HHS announcement, click here: https://www.federalregister.gov/documents/2020/05/14/2020-10045/patient-protection-and-affordable-care-act-hhs-notice-of-benefit-and-payment-parameters-for-2021

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