Although the Cadillac Tax implementation has been delayed two years, employers have started moving to adopt high-deductible health plans (HDHP) with health saving accounts (HSAs) to prepare for this new excise tax.
But with such a change, it’s important to ensure a plan is both ACA compliant and HSA compatible. Just because it is compliant with one law does not necessarily mean it is compliant with another.
One difference between being ACA compliant and HSA compatible is the out-of-pocket limits. For 2016, the HSAs limits are $6,550 for self-only and $13,100 for families. The ACA limits are slightly higher, $6,850 for self-only coverage and $13,700 for other than self-only coverage. Employers offering HDHP/HSA plans must ensure that they are satisfying the lower IRS out-of-pocket maximums for HDHPs, not the higher ACA limits.
Additionally, no one individual can be subject to more than the single-plan maximum under the ACA. “The self-only maximum annual limitation on cost sharing applies to each individual, regardless of whether the individual is enrolled in self-only coverage or in coverage other than self-only,” according to the Department of Labor. This applies to “all non-grandfather group health plans, including non-grandfather self-insured and large group health plans.” This means for family HDHP coverage, no one family member can incur more than the per-individual ACA maximum out-of-pocket of $6,850, while the family aggregate amount cannot exceed the maximum HDHP out-of-pocket of $13,100.
The ACA and HSA limits are release each year at different times, making annual plan evaluations a good idea. Plan sponsors should review current and proposed HDHP/HSA arrangements and update plan documents and enrollment materials as needed to reflect the new limits.
Corporate Health Systems 