A summary of certain 2023 health and welfare benefit plan limits

The IRS released Rev. Proc. 2022-24 on April 29, 2022, containing the 2023 high deductible health plan (HDHP) and health savings account (HSA) annual limits. The U.S. Department of Health & Human Services also previously released the 2023 annual limits for non-grandfathered medical plans subject to the Affordable Care Act (ACA).

The following limits apply to plan years beginning during the applicable calendar year. Limits for 2022 and 2023 are shown below for comparison purposes.
 

Please note that although the above deductible and out-of-pocket maximum limits apply on a plan year basis based on when plan year began, the health savings account (HSA) contribution limits will apply on a calendar year basis (regardless of the plan year for the underlying HDHP).
 

2023 maximum amount for Excepted Benefit HRA

IRS Rev. Proc. 2022-24 also includes the 2023 revised annual contribution limit for Excepted Benefit HRAs. The maximum annual HRA contribution is $1,950 for plan years that begin in 2023.

Excepted Benefit HRAs were created in late 2017 via a Presidential Executive Order. If it meets certain conditions, an Excepted Benefit HRA is exempt from the ACA’s plan design mandates, allowing an employer to offer it on a standalone basis. Excepted Benefit HRAs may reimburse general medical expenses and premiums for COBRA, short-term limited duration insurance, and other excepted benefits coverage.

Still to come

The 2023 annual limits for health flexible spending accounts, qualified transportation benefits, and adoption assistance will appear later this year.

[1] This limit does not apply to plans that remain grandfathered under the ACA. Embedded out-of-pocket maximums (OOPMs) are required for non-grandfathered plans with family OOPMs that fall above the ACA limit. A qualified HDHP plan must meet the HDHP limits as well as the ACA limits.

[2] If an HDHP uses an embedded deductible for family coverage, limiting the amount each individually covered family member must pay before the annual deductible is met, the embedded individual deductible must be no less than the family minimum statutory annual deductible to maintain qualified HDHP status.