January 26, 2023
On December 12, 2022, the Department of Health and Services (HHS) and Centers for Medicare and Medicaid Services (CMS) published the Notice of Benefit and Payment Parameters for 2024 Proposed Rule, along with an accompanying press release and fact sheet. The annual Notice details regulatory updates for public marketplaces and other Affordable Care Act (ACA) requirements. Within the fact sheet, HHS and CMS announced the updated inflation-adjusted out-of-pocket maximums for non-health savings account (HSA)/high-deductible health plan (HDHP) group health plans. The 2024 maximum annual limitation on cost sharing that a group health plan can impose for the 2024 plan year is $9,450 for individual coverage and $18,900 for family coverage, a roughly +3.8% increase over the 2023 limits. The 2024 maximums (with information for previous years) can be found below:
Out-of-Pocket Maximums by Year |
||||
|---|---|---|---|---|
|
|
HSA/HDHPs |
All Other Group Health Plans |
||
|
|
Self-Only |
Family |
Self-Only |
Family |
|
2024 |
TBA |
TBA |
$9,450* |
$18,900 |
|
2023 |
$7,500 |
$15,000 |
$9,100* |
$18,200 |
|
2022 |
$7,050 |
$14,100 |
$8,700* |
$17,400 |
|
2021 |
$7,000 |
$14,000 |
$8,550* |
$17,100 |
|
2020 |
$6,900 |
$13,800 |
$8,150* |
$16,300 |
|
2019 |
$6,750 |
$13,500 |
$7,900* |
$15,800 |
|
2018 |
$6,650 |
$13,300 |
$7,350* |
$14,700 |
|
2017 |
$6,550 |
$13,300 |
$7,150* |
$14,300 |
|
2016 |
$6,550 |
$13,100 |
$6,850* |
$13,700 |
|
2015 |
$6,450 |
$12,900 |
$6,600 |
$13,200 |
|
2014 |
$6,350 |
$12,700 |
$6,350 |
$12,700 |
* Embed self-only out-of-pocket maximum for family coverage
Under a new policy change beginning this year, as finalized in the HHS Notice of Benefit and Payment Parameters for 2022 and Pharmacy Benefit Manager Standards (2022 Payment Notice Part 2), HHS will publish the following limits by January of the year preceding the applicable benefit year: (i) premium adjustment percentage, (ii) maximum annual limitation on cost sharing, (iii) reduced maximum annual limitation on cost sharing and (iv) required contribution percentage.
Next Steps
- Employers should consider these inflation-adjusted limits when planning for the 2024 plan year.
- The Internal Revenue Service (IRS) establishes the annual inflation-adjusted amounts for health savings accounts (HSAs) paired with high-deductible health plans (HDHPs) via revenue procedure. The Business Group will update members on these dollar amounts applicable for the 2024 plan year when the IRS publishes them later in the year.
Resources
- HHS – Fact Sheet: Premium Adjusted Percentage, Maximum Annual Limitation on Cost Sharing, Reduced Maximum Annual Limitation on Cost Sharing, and Required Contribution Percentage for the 2024 Benefit Year
- HHS – Notice of Benefit and Payment Parameters for 2024 Proposed Rule
- HHS – Press Release: HHS Notice of Benefit and Payment Parameters for 2024 Proposed Rule
If you have questions, comments, or concerns about these or other regulatory and compliance issues, please contact us.
We provide this material for informational purposes only; it is not a substitute for legal advice.
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