Cheiron - 2023 Maximum Out-of-Pocket Limits, HSA Parameters, and Excepted Benefit HRA Limits

2023 Maximum Out-of-Pocket Limits, HSA Parameters, and Excepted Benefit HRA Limits

The Department of Health and Human Services (HHS) published the Maximum Annual Limitation on Cost Sharing limits for 2023. In addition, the IRS published (in Rev. Proc. 2022-24) the 2023 inflation adjusted amounts for Health Savings Accounts (HSAs) and the maximum amount that may be made newly available for an Excepted Benefit Health Reimbursement Arrangement (EBHRA). The chart below compares this year’s limits and parameters to the 2023 limits.

Background on Maximum Out-of-Pocket (MOOP)

As reflected in the chart below, the final 2023 rule increased MOOP limits for Essential Health Benefits (EHB) for plan years beginning after December 31, 2022, by $400 for self only coverage and $800 for family coverage. EHB include medical, behavioral health, and pharmacy benefits. These limits are applicable for all non-grandfathered plans and include in-network copays, deductibles, and coinsurance amounts.

Background on HSA Parameters

The chart also shows HSA inflation-adjusted parameters for 2023. Plans offering HSAs must comply with the contribution limits as well as the minimum deductible and maximum out-of-pocket limitations.

Background on EBHRAs

Under Treasury Regulation § 54.9831-1(c)(3)(viii) certain group health HRAs can qualify as limited excepted benefits (i.e., EBHRAs) that is primarily intended to be used to purchase short-term, limited duration health insurance not subject to certain group health plan requirements. See our Alert from September 19, 2019, for more information on EBHRAs.

Regulation § 54.9831-1(c)(3)(viii)(B) states that amounts newly made available, i.e., contributions into an HRA, for each plan year under an excepted benefit HRA may not exceed $1,800, but that for plan years beginning after December 31, 2020, this amount is increased by the chained CPI-U. Rev. Proc. 2022-24 provides that for plan years beginning in 2023, the maximum amount is increased to $1,950, representing the first increase from the original $1,800 limit.

MOOP Limits, HSA Parameters, and EBHRA Limits
Parameter	2023	2022
In-Network MOOP on EHB for non- grandfathered health plans	Self Only $ 9,100	Self Only $ 8,700
	Family¹ $18,200	Family $17,400
Maximum Contributions to an HSA (whether by employer or employee)	Self Only $ 3,850	Self Only $ 3,650
	Family $ 7,750	Family $ 7,300
Minimum Deductible for an HSA Qualified High Deductible Health Plan (HDHP)	Self Only $ 1,500	Self Only $ 1,400
	Family $ 3,000	Family $ 2,800
In- Network MOOP for an HDHP paired with an HSA	Self Only $ 7,500	Self Only $ 7,050
In- Network MOOP for an HDHP paired with an HSA	Family $15,000	Family $14,100
Maximum Contributions for EBHRA	$ 1,950	$ 1,800

If you have any questions about these or other limits or about the impact on your plan, contact your Cheiron consultant.

Cheiron is an actuarial consulting firm that provides actuarial and consulting advice. However, we are neither attorneys nor accountants. Accordingly, we do not provide legal services or tax advice.

¹Note plans with family MOOP limits must apply the self-only limit for each person enrolled in family coverage. This means that once a person covered under a family plan reaches the self-only MOOP limit, then all expenses above the self-only limit for covered EHBs for that person must be reimbursed at 100%, even if the family MOOP limit has not been met.