June 06, 2019

IRS Releases “Modest” 2020 Inflation Adjustments to HSAs and High Deductible Health Plans

In Rev. Proc. 2019-25, the IRS announced the 2020 inflation adjustments to HSAs and high deductible health plans.  The IRS previously has explained that a high deductible health plan that is a group health plan will generally be subject to both the out-of-pocket maximum for high deductible health plans under Section 223 and the out-of-pocket maximum for group health plans under Section 1302(c)(1) of the ACA. If two different out-of-pocket maximum levels apply to a plan, the plan complies with both if it complies with the lower out-of-pocket maximum. Thus, in the case of a high deductible health plan subject to the maximum out-of-pocket limit under Section 223 and the maximum out-of-pocket limit under Section 2706(b) of the Public Health Service Act, the plan must comply with the lower amount. In any event, a high deductible health plan must satisfy the maximum out-of-pocket limit under Section 223 to be a high deductible health plan supporting an HSA.