New HSA and HDHP Rules from the IRS

The Internal Revenue Service (IRS) has released Revenue Procedure 2025-19, outlining the inflation-adjusted limits for Health Savings Accounts (HSAs) and High-Deductible Health Plans (HDHPs) for calendar year 2026. These annual adjustments are crucial for individuals and employers offering or utilizing these popular tax-advantaged health benefits. Let’s break down the key changes and their implications.

The Core Changes for 2026

Rev. Proc. 2025-19 details several important increases, reflecting the rising costs of healthcare and living. Here’s a summary of the adjusted limits:

1. HSA Contribution Limits:

  • Self-Only Coverage: The annual HSA contribution limit for individuals with self-only HDHP coverage will increase to $4,400 (up from $4,300 in 2025).
  • Family Coverage: For individuals with family HDHP coverage, the annual HSA contribution limit will rise to $8,750 (up from $8,550 in 2025).
  • Catch-Up Contributions: The additional “catch-up” contribution for individuals aged 55 or older remains unchanged at $1,000. This amount is set by statute and is not subject to inflation adjustments.
  • Note: Under currently proposed legislation, annual contribution limits for HSAs would double, jumping to $8,600 for individuals with self-only coverage and to $17,100 for family coverage. However, the increased contribution phases out for adjusted gross incomes between $75,000 and $100,000 (individual) and $150,000 to $200,000 (joint filers with family coverage).

2. High-Deductible Health Plan (HDHP) Definitions:

To qualify as an HDHP, health plans must meet specific deductible and out-of-pocket maximum thresholds. These too have been adjusted for 2026:

  • Minimum Annual Deductible:
    • Self-Only Coverage: The minimum annual deductible for self-only HDHP coverage will be $1,700 (up from $1,650 in 2025).
    • Family Coverage: The minimum annual deductible for family HDHP coverage will be $3,400 (up from $3,300 in 2025).
  • Maximum Out-of-Pocket Expenses (excluding premiums):
    • Self-Only Coverage: The maximum out-of-pocket expense limit (including deductibles, copayments, and coinsurance, but not premiums) for self-only HDHP coverage will be $8,500 (up from $8,300 in 2025).
    • Family Coverage: The maximum out-of-pocket expense limit for family HDHP coverage will be $17,000 (up from $16,600 in 2025).

3. Excepted Benefit Health Reimbursement Arrangements (EBHRAs):

  • For plan years beginning in 2026, the maximum amount that may be newly available for an excepted benefit HRA is $2,200 (up from $2,150 in 2025).

How HSA and HDHP Changes Affect Businesses

These adjustments have several implications for employers who offer HDHPs and HSAs:

  • Benefit Plan Design: Employers should review their current HDHP offerings to ensure they meet the new minimum deductible and maximum out-of-pocket limits for 2026. Plans that fall outside these parameters will not qualify as HDHPs, and employees enrolled in them will not be eligible to contribute to an HSA.
  • Contribution Strategies: Businesses that contribute to employee HSAs will need to update their payroll systems and contribution schedules to reflect the higher maximum contribution limits. This presents an opportunity to encourage greater employee savings for healthcare costs.
  • Communication with Employees: Employers must clearly communicate these updated limits to their employees well in advance of the 2026 plan year. This ensures employees can make informed decisions about their healthcare elections and HSA contributions.
  • Compliance: Staying abreast of these annual adjustments is crucial for maintaining compliance with IRS regulations. Employers should work with their benefits administrators or legal counsel to ensure their plans and communications adhere to the new guidelines.

How HSA and HDHP Changes Affect Employees

For employees, the adjustments to HSAs and HDHPs offer both opportunities and considerations:

  • Increased Savings Potential: The higher HSA contribution limits mean employees can save more pre-tax money for qualified medical expenses. This can be a significant advantage, as HSA funds roll over year-to-year and can be invested, growing tax-free.
  • Higher Deductibles and Out-of-Pocket Maximums: While HSAs offer tax advantages, the corresponding HDHPs come with higher deductibles. Employees should be aware that they will need to pay more out-of-pocket before their insurance coverage kicks in. This reinforces the importance of building up their HSA balances.
  • Financial Planning: These changes underscore the need for employees to proactively plan for their healthcare expenses. Maximizing HSA contributions can help mitigate the impact of higher deductibles and out-of-pocket costs.
  • Reviewing Healthcare Choices: Employees should evaluate their healthcare needs and financial situation in light of these new limits when making their benefit selections during open enrollment. An HDHP coupled with an HSA may be a good fit for those who are generally healthy and want to save for future medical costs, but it’s important to understand the associated risks and benefits.
  • For more information about tax changes that may affect employees, take a look at Tax Year 2025: A Summary of Important Changes.

Next Steps

As the 2026 plan year approaches, businesses and employees should:

  • For Businesses: Review existing HDHP plans and contribution strategies, update payroll and benefits systems, and prepare clear communications for employees.
  • For Employees: Understand the new contribution limits and HDHP requirements, consider increasing HSA contributions, and factor these changes into their overall financial and healthcare planning.

These annual adjustments are a routine part of the HSA and HDHP landscape. By understanding and adapting to these changes, both employers and employees can continue to leverage the benefits of these important healthcare savings tools.

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