In the most recent sign that special COVID-19 benefit plan rules are drawing to a close, last Friday, the IRS issued Notice 2023-37, which clarifies the scope of COVID-19 testing and treatment that can be provided on a pre-deductible basis under a high deductible health plan (HDHP) without impacting a participant’s ability to contribute to a health savings account (HSA). As a reminder, if an HDHP covers medical items and services before the participant satisfies the IRS minimum deductible (self-only or family), that coverage may disqualify the participant’s HSA contributions. Notice 2023-37 can be downloaded here.
High-Deductible Health Plan
A New Normal? Omnibus Bill Extends High Deductible Health Plan Telehealth Safe Harbor
By Katrina McCann & Jesse T. Foley on
The Consolidated Appropriations Act of 2023 (“CAA 2023”), signed into law on December 29, introduced sweeping reforms to the employee benefits landscape. Not only do the CAA 2023’s “SECURE 2.0” provisions make some significant changes for retirement plans, but CAA 2023 also extends the telehealth plan safe harbor for high-deductible health plans (“HDHPs”) that…
Executive Order Seeks to Improve Consumer-Driven Healthcare
On June 24, 2019, the President issued his Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First. The Executive Order directs regulators to take action to improve healthcare price transparency and to enhance consumer-driven healthcare. The success of consumer-driven healthcare is dependent on patients being able to act as…
IRS Announces HSA and HDHP Limitations for 2020
By Damian A. Myers on
On May 28, 2019, the IRS released Revenue Procedure 2019-25 setting dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2020. HSAs are subject to annual aggregate contribution limits (i.e., employee and dependent contributions plus employer contributions). HSA participants age 55 or older can contribute additional catch-up contributions. Additionally, in order…
IRS Announces HSA and HDHP Limitations for 2019
By Damian A. Myers on
On May 10, 2018, the IRS released Revenue Procedure 2018-30 setting dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2019. HSAs are subject to annual aggregate contribution limits (i.e., employee and dependent contributions plus employer contributions). HSA participants age 55 or older can contribute additional catch-up contributions. Additionally, in order…
IRS Transition Relief Reinstates $6,900 Family Limit for 2018 HSAs
By Damian A. Myers on
On April 26th, the IRS released Rev. Proc. 2018-27, effectively reinstating a $6,900 limit on 2018 health savings account (“HSA”) contributions for family coverage. This is welcome relief for individuals who planned on contributing the maximum permitted HSA contributions for 2018 as well as employers who offer plans that facilitate these contributions.…
IRS Reduces 2018 Health Savings Account Limit for Family Coverage
By Damian A. Myers on
On March 5, 2018, the IRS released Revenue Procedure 2018-18, which, among other things, adjusts downward the 2018 total contribution limit to health savings accounts (HSAs) for individuals enrolled in family coverage. In late 2017, the IRS announced that the 2018 HSA limit for individuals enrolled in family coverage would be $6,900. The recently…
IRS Announces HSA and HDHP Limitations for 2018
By Damian A. Myers on
On May 4, 2017, the IRS released Revenue Procedure 2017-37 setting dollar limitations for health savings accounts (HSAs) and high-deductible health plans (HDHPs) for 2018. HSAs are subject to annual aggregate contribution limits (i.e., employee and dependent contributions plus employer contributions). HSA participants age 55 or older can contribute additional catch-up contributions. Additionally, in order…