HDHP and HSA Annual Limits Increase for 2022

The Internal Revenue Service (IRS) recently announced in Revenue Procedure 2021-25 that some of the annual limits affecting high deductible health plans (HDHPs) and health savings accounts (HSAs) will increase for calendar year 2022.

In order to maintain an HDHP's HSA-eligible status, an employer sponsoring an HSA-eligible HDHP in 2022 will need to ensure that the HDHP's annual deductible is at least $1,400 for self-only coverage and $2,800 for family coverage. These amounts remained the same as they were for calendar year 2021.

The maximum annual out-of-pocket expense that can be incurred by a participant in an HDHP has increased for calendar year 2022 to $7,050 for self-only coverage (up from $7,000 for 2021) and $14,100 for family coverage (up from $14,000 for 2021). These limits apply to all deductibles, co-payments, coinsurance, and other out-of-pocket amounts on a combined basis, but they do not include premiums.

It is important for employers to keep in mind that maximum out-of-pocket expense limits also apply under the Patient Protection and Affordable Care Act of 2010 (ACA) for all "non-grandfathered" employer-sponsored group health plans, even if the plans are not HDHPs. Thus, non-HDHPs may not have out-of-pocket maximums in 2021 that exceed $8,550 for self-only coverage and $17,100 for family coverage. The ACA maximums for 2022 are $8,700 for self-only coverage and $17,400 for family coverage.

The maximum contribution an individual may make to an HSA has also increased. For calendar year 2022, the maximum annual HSA contribution limits are $3,650 for an individual with self-only coverage under an HDHP and $7,300 for an individual with family coverage under an HDHP. The contribution limits for calendar year 2021 were $3,600 and $7,200, respectively. The additional amount that individuals who are age 55 or older may contribute is set by statute and remains at $1,000 for 2022.

For more information about these annual limits, please contact Gary Blachman, Audra Ferguson-Allen, Sarah Funke, Robert Gauss, Melissa Proffitt, Shalina Schaefer, Kathleen Sheil Scheidt, Tara Sciscoe, Chris Sears or the Ice Miller LLP Employee Benefits attorney with whom you work.

This publication is intended for general information purposes only and does not and is not intended to constitute legal advice. The reader should consult with legal counsel to determine how laws or decisions discussed herein apply to the reader’s specific circumstances.