Cheiron - HHS Sets 2022 Maximum Out-of-Pocket Limits; IRS Releases HSA Parameters for 2022

HHS Sets 2022 Maximum Out-of-Pocket Limits; IRS Releases HSA Parameters for 2022

On May 5, 2021, the Department of Health and Human Services (HHS) published the Notice of Benefit and Payment Parameters for 2022 and Pharmacy Benefit Manager Standards (hereinafter the “final 2022 rule”), which finalizes maximum annual limitations on out-of-pocket cost sharing that are $400 (for self-only) and $800 (for family) below what HHS proposed in November 2020¹. HHS also issued a fact sheet that summarizes the key provisions of the final 2022 rule. In addition, on May 10, 2021, the IRS issued Rev. Proc. 2021-25, which provides the 2021 inflation adjusted amounts for Health Savings Accounts (HSAs) as determined under Code Section 223.

Maximum Out-of-Pocket and HSA Limits for 2022

As reflected in the chart below, the final 2022 rule increased Maximum Out-of-Pocket limits for Essential Health Benefits (EHB) for plan years beginning after December 31, 2021, by $150 for self only coverage and $300 for family coverage. The chart below also shows HSA inflation-adjusted parameters for 2022. The limits in the chart are applicable for all non-grandfathered plans.

Maximum Out-of-Pocket Limits (MOOP) and HSA Parameters
Parameter	2022	2021
In-Network MOOP on EHBs for non- grandfathered health plans	Self Only $ 8,700	Self Only $ 8,550
	Family $17,400	Family² $17,100
Maximum Contributions to an HSA Account (whether by or on behalf of an employee)	Self Only $ 3,650	Self Only $ 3,600
	Family $ 7,300	Family $ 7,200
Minimum Deductible that an HSA-Qualified High Deductible Health Plan (HDHP) can have	Self Only $ 1,400	Self Only $ 1,400
	Family $ 2,800	Family $ 2,800
Maximum In-Network Out-Of- Pocket for an HDHP paired with an HSA	Self Only $ 7,050	Self Only $ 7,000
	Family $14,100	Family $14,000

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.

¹The proposed 2022 rule was published in the Federal Register on December 4, 2020 (85 FR 78572). The proposed 2022 rule stated that the 2022 benefit year maximum annual limitation on cost sharing would be $9,100 for self-only coverage and $18,200 for other than self-only coverage.

²Note 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.