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2021 Out-of-Pocket Limits, HDHP Minimum Deductibles, and HSA Contribution Limits

Overview

The Department of Health and Human Services and the IRS have announced the finalized out-of-pocket limits, HDHP minimum deductibles, and HSA contribution limits for 2021. We are sharing these numbers now to assist plan sponsors that are starting to evaluate plan design changes for the next year.

Out-of-Pocket Limits

The Department of Health and Human Services has announced the final notice of increases to the out-of-pocket maximum dollar limits for plan years beginning January 1, 2021 (regulations available here). The table below shows the changes in out-of-pocket limits from 2018 to 2021. Note that the 2021 amounts represent an increase of nearly 5% from the 2020 maximums.

ACA OOP Limits for Non-Grandfathered Health Plans

HDHP Limits

The IRS has released Revenue Procedure 2020-32, setting dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for calendar year 2021. The table below shows the contribution, deductible, and out-of-pocket limit changes from 2018 through 2021.

Contribution and OOP Limits for HSA and HDHP

Interaction Between Two Out-of-Pocket Limits

Employers who sponsor health plans that must comply with both the ACA and IRS out-of-pocket limits should note that the ACA limits continue to be higher than the IRS amounts. In 2021, the ACA limit for self-only coverage will be $1,550 more than that for HDHPs and $3,100 more for family coverage. CMS has issued some useful guidance for plan designs with non-embedded out-of-pocket limits, which can be found here.

Please contact your MedCost Account Manager if you have any questions.