On April 23, the Internal Revenue Service released Rev. Proc. 2014-30, which provides the following 2015 inflation-adjusted limits applicable to Health Savings Accounts (HSA) and High Deductible Health Plans (HDHP):

• 2015 HSA Maximum Contribution Limits
  • Self-Only HDHP Coverage: $3,350
  • Family HDHP Coverage: $6,650

• 2015 HDHP Minimum Deductible Limits
  • Self-Only HDHP Coverage: $1,300
  • Family HDHP Coverage: $2,600

• Out-of-Pocket Maximum Limits*
  • Self-Only HDHP Coverage: $6,450
  • Family HDHP Coverage: $12,900

*In 2014, the HDHP out-of-pocket maximum limit matched the PPACA out-of-pocket maximum limit applicable to all non-grandfathered group health plans. However, this is not the case for 2015 and beyond. The Department of Health and Human Services has announced that the 2015 PPACA out-of-pocket maximum limits will be $6,600 for self-only coverage and $13,200 for family coverage.

This divergence occurred because the PPACA limit is indexed to the “premium adjustment percentage,” which is defined as the percentage (if any) 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. The HSA and HDHP limits, on the other hand, are subject to a different a cost-of-living adjustment based on the Consumer Price Index for All-Urban Consumers (CPI-U).

A non-grandfathered HDHP will need to comply with the lower of the two applicable out-of-pocket limits. For 2015, this means that a non-grandfathered HDHP’s out-of-pocket maximums cannot exceed $6,450/$12,900 based on the lower IRC § 223 HDHP limits. A non-grandfathered group health plan that is not an HDHP will be subject only to the higher $6,600/$13,200 PPACA out-of-pocket maximum limits. Grandfathered non-HDHP group health plans are not required to impose an out-of-pocket maximum of any amount.