As if keeping up with the annual out-of–pocket (OOP) maximum requirements was not confusing enough, the Internal Revenue Services (IRS) and the Department of Health and Human Services (HHS) are using different indexes when making annual adjustments for inflation. The IRS recently announced that the OOP maximum for high deductible health plans (HDHP) will be $6,450 for single coverage and $12,900 for family tiers in 2015. In January, HHS announced that the 2015 under the Affordable Care Act (ACA) OOP limits will be $6,600 for self-only coverage and $13,200 for family tiers.
Of note, these maximums are NO LONGER THE SAME as the ACA out of pocket maximum under healthcare reform rules. For 2014, these amounts were linked together, presumably to help avoid confusion and provide consistency. Unfortunately, moving forward these amounts will be linked to different indexes.
The maximum HDHP out-of-pocket maximum set by the IRS are tied to the Consumer Price Index. The ACA out of pocket limits are set annually by HHS using the premium adjustment percentage (the percentage by which the average per capita premium for health insurance coverage in the United States for the preceding calendar year exceeds such average per capita premium for 2013).
We all know that healthcare spending has outpaced increases in all other areas of our economy so this gap between the ACA limits and HDHP limits is likely to continue. One would hope that the government would use a consistent index when setting limits so that an employer looking to put in place an HSA compatible plan could utilize the maximum limits afforded under the ACA. Until such consistency is available, employers who wish to offer an HSA compatible HDHP in 2015 must comply with the lower OOP maximums.