The Department of Health and Human Services (HHS) recently announced the proposed 2024 Benefit Parameters, outlining the maximum out-of-pocket (OOP) limits applicable to non-grandfathered plans for plan years beginning in 2024. Each year, these OOP maximums are adjusted for inflation. Last year, HHS pledged to release the updated amounts “…by January of the year preceding the applicable benefit year…” and they have indeed stuck to that promise.
Under the Affordable Care Act (ACA), non-grandfathered health plans are required to comply with an overall annual limit on out-of-pocket expenses for essential health benefits, regardless of whether the plan is self-funded or fully insured. The current limits applicable to 2023 plan years is $9,100 for self-only coverage and $18,200 for family coverage. The 2024 limits will be raised to $9,450 for self-only coverage and $18,900 for family coverage, respectively.
Here's a summary of the amounts for traditional plans for the 2023 / 2024 plan years for reference:
High-deductible health plans (HDHPs) with Health Savings Accounts (HSAs) feature different limits than traditional plans, including OOP maxes, along with deductible and contribution limits. The 2024 HDHP/HSA limits have yet to be released by the IRS. Historically these are released in May of each year and will be communicated when available.
Although, it should be noted in the interim that if your plans offer both traditional and HDHP/HSA plans (that are not grandfathered), your plans are subject to both sets of requirements and you must ensure compliance with the lowest applicable out-of-pocket maximum. Plus, the ACA requires that a per person (individualized/embedded) out-of-pocket maximum doesn't exceed the ACA limit, even if you are in the larger (family) tier. This assists single family members in accessing benefits sooner without having to hit the full amount for the family tier.
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