2021 Plan Limits and Final Coupon Guidance Released


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May 27, 2020

IRS Announces 2021 HDHP Limits

Now that the U.S. Department of Health & Human Services (HHS) has released its Notice of Benefit and Payment Parameters for 2021 and the IRS has released Rev. Proc. 2020-32, we know the 2021 cost-of-living adjustments for non-grandfathered plans subject to the Affordable Care Act (ACA), high-deductible health plans (HDHPs), and health savings accounts (HSAs). For comparison purposes, the 2020 and 2021 limits are below:

ACA Limits




Out-of-Pocket Maximum Limit[1]

Self-only: $8,550

Family: $17,100

Self-only: $8,150

Family: $16,300






HDHP Minimum Deductible

Self-only: $1,400

Family: $2,800

Self-only: $1,400

Family: $2,800

HDHP Maximum Out-of-Pocket

Self-only: $7,000

Family: $14,000

Self-only: $6,900

Family: $13,800

HSA Annual Contribution Maximum

Self-only: $3,600

Family: $7,200

Self-only: $3,550

Family: $7,100

HSA Catch-up Contribution Limit (age 55 and older)



Final Rules for Drug Coupons and HDHPs

The Notice of Benefit and Payment Parameters for 2021 also contains guidance on the application of prescription drug manufacturer coupons (“coupons”) and out-of-pocket maximum limits. Last year, the Notice of Benefit and Payment Parameters for 2020 announced that insurers and group health plans could exclude a coupon for a brand-name drug from a participant’s out-of-pocket maximum limit only if there was a medically appropriate generic available. The enforcement of this provision was suspended because of concerns about HSA eligibility if a participant was enrolled in a HDHP. The concern was that participants were becoming ineligible to contribute, or receive contributions, to their HSAs if the participant was being credited for the full value of the drug to their deductible but only paying a fraction of the cost. Currently, discounts must be ignored when determining if a participant met their HDHP deductible.

Under the 2021 Notice, the DOL allows, but does not require, group health plans to exclude the value of prescription drug coupons from a participant’s out-of-pocket maximum. This is no longer dependent on a medically equivalent generic being available. Keep in mind some states may have laws that impact how fully insured plans manage discounts.

[1] This limit does not apply to plans that remain grandfathered under the ACA.

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