2025 Maximum Out-of-Pocket Limits, HSA Parameters, and Excepted Benefit HRA Limits
The Department of Health and Human Services (HHS) published the Maximum Annual Limitation on Cost-Sharing for 2025. In addition, the IRS published (in Rev. Proc. 2024-25) the 2025 inflation-adjusted amounts for Health Savings Accounts (HSAs) and the maximum amount that may be made newly available for an Excepted Benefit Health Reimbursement Arrangement (EBHRA). The chart below compares this year’s limits and parameters to the 2025 limits. For the first time, the maximum out-of-pocket limits for non-grandfathered health plans will decrease.
Background on Maximum Out-of-Pocket Limitations (MOOP Limits)
As reflected in the chart below, the MOOP Limits for Essential Health Benefits (EHB) for lan years beginning after December 31, 2024 have decreased by $250 for self only coverage and $500 for family coverage. EHB includes medical, behavioral health, and pharmacy benefits. These limits are applicable for all non-grandfathered plans and include in-network copays, deductibles, and coinsurance amounts.
Background on HSA Parameters
The chart also shows HSA inflation-adjusted parameters for 2025. Plans offering HSAs must comply with the contribution limits as well as the minimum deductible and maximum out-of-pocket limitations. These limits will increase for 2025.
Background on EBHRAs
Under Treasury Regulation § 54.9831-1(c)(3)(viii) certain group health HRAs can qualify as limited excepted benefits (i.e., EBHRAs) that are primarily intended to be used to purchase short-term, limited duration health insurance not subject to certain group health plan requirements. See our Alert from September 19, 2019 for more information on EBHRAs.
Regulation § 54.9831-1(c)(3)(viii)(B) originally stated that amounts newly made available, i.e., contributions into an HRA, for each plan year under an excepted benefit HRA may not exceed $1,800, but that for plan years beginning after December 31, 2020, this amount is increased by the chain-weighted CPI-U. The increased amount is published in Rev. Proc. 2024-25 for 2025.
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MOOP Limits, HSA Parameters, and
EBHRA Limits
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Parameter
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2025
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2024
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In-Network MOOP Limits on EHB for non- grandfathered health plans
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Self Only
$ 9,200
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Self Only
$ 9,450
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Family1
$18,400
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Family1
$18,900
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Maximum Contributions to an HSA (whether by employer or employee)
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Self Only
$ 4,300
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Self Only
$ 4,150
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Family
$ 8,550
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Family
$ 8,300
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Minimum Deductible for an HSA Qualified High Deductible Health Plan (HDHP)
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Self Only
$ 1,650
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Self Only
$ 1,600
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Family
$ 3,300
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Family
$ 3,200
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In-Network MOOP for an HDHP paired with an HSA
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Self Only
$ 8,300
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Self Only
$ 8,050
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Family
$16,600
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Family
$16,100
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Maximum Contributions for EBHRA
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$ 2,150
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$ 2,100
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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 not attorneys, accountants, or clinicians. Accordingly, we do not provide legal services, tax advice, or medical advice.
1 Plans with family MOOP Limits must also 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.