Oops… did someone forget to look at HDHPs when determining maximum out-of-pocket expenses (OOPs) under the Affordable Care Act?
Through 2014, the out-of-pocket maximums for ACA-compliant health plans have matched the out-of-pocket maximums for the high-deductible health plans (HDHPs) that allow individuals and families to open and contribute to a Health Savings Account (HSA). But in 2015, out-of-pocket maximums required for HSA-compatible HDHPs will differ from out-of-pocket maximums set by the ACA for the first time.
For 2015, HSA-compatible HDHPs will have out-of-pocket maximums of $6,450 for individual coverage and $12,900 for family coverage. In 2015, the ACA will allow plans to have higher out-of-pocket maximums, of $6,600 for individual coverage and $13,200 for family coverage.
This occurs because the IRS sets maximums for HDHPs based on inflation rates. But the ACA requires the U.S. Department of Health and Human Services, which administers the ACA, to adjust deductible and out-of-pocket “cost-sharing” maximums each year using a premium adjustment percentage, or the estimated change in average insurance premiums. Health insurance costs are increasing faster than the general inflation rate, so the gap between out-of-pocket maximums allowed under the ACA and out-of-pocket maximums allowed for an HDHP to be linked to a health savings account will likely increase as years pass.
The takeaway for employers? Remember that a plan that meets the criteria for a high-deductible health plan under the ACA might not qualify your employees to enroll in an HSA.