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"2025
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2025 HSA Contribution, HDHP Cost-Sharing Limits

The IRS has announced significantly higher health savings account contribution limits for 2025, with the amount increasing 3.6% for individual HSA plans.

The IRS updates this amount annually, along with minimum deductibles as well as the out-of-pocket maximums for high-deductible health plans. Under its rules, HSAs, which help employees save for medical expenses, are only available to those enrolled in qualified HDHPs.

Understanding these amounts now can help you get an early start on human resources planning for next year.

Here are the changes coming in 2025:

HSA annual contribution limit

  • Self-only plan: $4,300, up from $4,150 in 2024
  • Family plan: $8,550, up from £8,300 in 2024
  • Catch-up contribution (for those aged 55 and older): $1,000 (unchanged)

HDHP minimum annual deductible

  • Individual plan: $1,650, up from $1,600 in 2024
  • Family plan: $3,300, up from $3,200 in 2024

HDHP annual out-of-pocket maximum

  • Individual plan: $8,300, up from $8,050 in 2024
  • Family plan: $16,600, up from $16,100 in 2024

What to do

If you sponsor an HDHP for your staff, you should review the plan’s minimum deductible amount and maximum out-of-pocket expense limit when preparing for the 2025 plan year.

If you allow employees to make pre-tax contributions to an HSA, you should also update your plan communications to reflect the new amounts.

The many benefits of HSAs

An HSA is a special bank account for your employees’ eligible health care costs. They can put money into their HSA through pre-tax payroll deductions, deposits or transfers. As the amount grows over time, they can continue to save it or spend it on eligible medical and medical-related expenses.

Employers can also contribute to the accounts, but the annual contribution maximum applies to all contributions in total (from the employee and the employer).

The money in the HSA belongs to the employee and is theirs to keep, even if they switch jobs. If they go to a new employer that offers qualified HDHPs, they can continue to fund the account in their new job.

Funds roll over from year to year and can earn interest. Many plans also have investment options for the funds to help savers further grow the account.

There are a number of benefits for employees who have an HSA:

  • The money an employee contributes to an HSA is not subject to income taxes, which reduces their overall taxable income.
  • They are not taxed on withdrawals.
  • If employees contribute to their HSA with after-tax money, they can deduct their contributions during tax time on Form 1040.
  • Employees can tap the funds for any approved out-of-pocket medical expenses.
  • They can also grow the account tax-free by investing the funds in the account, sort of like a nest egg for medical expenses in retirement.

HSA-eligible expenses:

  • Payments for services or medicine that go towards health plan deductibles, copayments or coinsurance.
  • Dental or vision care (including orthodontics, eye exams, corrective lenses).
  • Medical devices.
  • Certain over-the-counter medicines, like pain relievers, allergy medication, cold and flu medicine, and menstrual products.
  • Vitamins and health supplements, if recommended by a medical or health professional for the treatment or prevention of a specific disease or condition.
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Worker Enrollment in HDHPs Falls

After enrollment in high-deductible health plans soared during the last decade, 2022 marked the first year that enrollment in these plans fell among American workers since 2013, according to a new report by ValuePenguin.

The insurance-review website found that 54% of U.S. workers signed up for HDHPs in 2022, compared to 56% in 2021. The dip, while seemingly small, represents millions of workers that have opted for other plans as employers are offering a greater variety of plans to their employees, including preferred provider organizations (PPOs) and health maintenance organizations.

Additionally, fewer are exclusively offering HDHPs to their employees. In 2022, 9% of employers with 20,000 or more workers offered HDHPs exclusively, a drop from 22% in 2018, according to Mercer’s “National Survey of Employer-Sponsored Health Plans.” And 10% of employers with 500 or more workers offered only these plans, compared to 13% in 2018.

Signs of weariness

There are signs that workers are growing weary of high out-of-pocket expenses associated with HDHPs and are more willing to pay a little extra in premium in exchange for lower deductibles, copays and coinsurance.

Indeed, workers who are enrolled in HDHPs are 30% less confident that they will know what their health care costs will be, compared to those who are enrolled in PPOs, which usually have lower deductibles, according to recent research by Arizent, a publisher of health insurance news. Seven in 10 HDHP enrollees also found their health care costs too expensive, compared to 50% of PPO enrollees.

Offering employees a choice of at least one other type of plan besides an HDHP can avoid blowback. It can create bad feelings if staff think their health plan offers little coverage thanks to a high deductible that they never reach. It hurts even more if they haven’t funded their health savings account (HSA), which often happens.

Additionally, if paying for medical costs becomes a burden, employees may forgo necessary care, likely worsening any conditions they are dealing with, which can affect their productivity at work as well. And if they have a medical emergency, they may have to take on debt to pay for the care.

A happy medium

First: HDHPs are not for everyone. People who have chronic conditions are not good candidates for these plans. A huge deductible before receiving coverage year after year can be a barrier to receiving care.

Fortunately, there are many HDHPs with relatively low deductibles. Under the law, for a plan to qualify as an HDHP it has to have a deductible of at least $1,600 for single coverage and $3,200 for family coverage.

If you can offer an HDHP with a deductible at or near the minimum, along with an attached HSA that you partially contribute to, the plan would be less burdensome for employees. And since HSAs are only available for individuals enrolled in HDHPs, employees need some additional education on the importance of HSAs.

The many benefits of HSAs

  • Employees contribute pre-tax dollars to the account.
  • Employers can also contribute to the account.
  • Funds withdrawn from the account to pay for qualified medical expenses are not taxed.
  • Funds in the account can be invested and build value over time, like a 401(k) plan.
  • HSAs can be moved when an employee switches jobs.
  • Funds can be used for medical expenses at any time, even in retirement.

Finally, HDHPs with a high deductible can be a real value for young and healthy individuals.

That’s because under federal law, an HDHP will pay for a number of basic procedures with no cost-sharing on the part of the enrollee for preventive care like checkups and screenings, which insurers must cover with no out-of-pocket expense on the part of health plan enrollees.

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Uncategorized

2024 HSA Contribution Limits, HDHP Minimums, Maximums Set

The IRS has raised the maximum amount employees can funnel into their health savings accounts by 7.8% for 2024, the largest increase ever, brought to you by inflation.

The IRS updates this amount annually, along with minimum deductibles as well as the out-of-pocket maximums for high-deductible health plans. Under its rules, HSAs, which help employees save for medical expenses, are only available to those enrolled in qualified HDHPs.

Understanding these amounts now can help you get an early start on human resources planning for next year.

Here are the changes coming in 2024:

HSA annual contribution limit

  • Self-only plan: $4,150, up 7.8% from $3,850 in 2023
  • Family plan: $8,300, up 7% from $7,750 in 2023
  • Catch-up contribution (for those aged 55 and older): $1,000 (unchanged)

HDHP minimum annual deductible

  • Individual plan: $1,600, up from $1,500 in 2023
  • Family plan: $3,200, up from $3,000 in 2023

HDHP annual out-of-pocket maximum

  • Individual plan: $8,050, up from $7,500 in 2023
  • Family plan: $16,100, up from $15,000 in 2023

Excepted benefit health reimbursement arrangement

  • Maximum annual employer contribution: $2,100, up from $1,950

The many benefits of HSAs

An HSA is a special bank account for your employees’ eligible health care costs. They can put money into their HSA through pre-tax payroll deductions, deposits or transfers. As the amount grows over time, they can continue to save it or spend it on eligible medical and medical-related expenses. 

Employers can also contribute to the accounts, but the annual contribution maximum applies to all contributions in total (from the employee and the employer). 

The money in the HSA belongs to the employee and is theirs to keep, even if they switch jobs. If they go to a new employer that offers qualified HDHPs, they can continue to fund the account in their new job.

Funds roll over from year to year and can earn interest. Many plans also have investment options for the funds to help savers further grow the account.

There are a number of benefits for employees who have an HSA:

  • The money an employee contributes to an HSA is not subject to income taxes, which reduces their overall taxable income.
  • They are not taxed on withdrawals.
  • If employees contribute to their HSA with after-tax money, they can deduct their contributions during tax time on Form 1040.
  • Employees can tap the funds for any approved out-of-pocket medical expenses.
  • They can also grow the account tax-free by investing the funds in the account, sort of like a nest egg for medical expenses in retirement. (That said, 62% of account holders spend the money on year-to-year or near-term expenses, according to a report by the Employee Benefit Research Institute.)

HSA-eligible expenses:

  • Payments for services or medicine that go towards health plan deductibles, copayments or coinsurance.
  • Dental or vision care (including orthodontics, eye exams, corrective lenses),
  • Medical devices.
  • Certain over-the-counter medicines, like pain relievers, allergy medication, cold and flu medicine, and menstrual products.
  • Vitamins and health supplements, if recommended by a medical or health professional for the treatment or prevention of a specific disease or condition.
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HDHP Enrollees Less Satisifed with Their Health Plans

A new study has found that people enrolled in traditional PPOs and HMOs are more satisfied with their plans than those who are enrolled in high-deductible health plans. But satisfaction greatly increases when HDHP enrollees stick with their plan for more than three years, according to the Employee Benefit Research Institute (EBRI)/Greenwald Research “Consumer Engagement in Health Care Survey.”

HDHP enrollees enjoy lower up-front premium costs in exchange for higher potential out-of-pocket costs for copays, coinsurance and deductibles, and high health care users may experience significant outlays not covered by insurance. The sticker shock that comes with paying for those deductibles is likely partly responsible for those feelings.

But the report authors noted that there may be other reasons too:

“Lack of experience with their health coverage may account — at least in part — for this difference. Higher out-of-pocket costs may also contribute to the difference in satisfaction, but other disconnects exist,” they wrote.

HDHP enrollees also were less satisfied about other aspects of their coverage, with the study finding that:

  • 47% of HDHP participants were satisfied with the cost of prescription drugs, compared to 63% of traditional plan enrollees.
  • 47% of HDHP participants were happy with the prices they pay for other health care services, compared to 57% of traditional plan members.

That said, the poll did not find any differences in terms of the perceived quality of care that HDHP and traditional plan enrollees receive.

The study authors also surmised that it is often people who are new to health insurance who may be most attracted to HDHPs due to the lower premiums. Similarly, those on a restricted budget may also gravitate towards these plans due to the lower premiums up front.

Interestingly, the survey found that the longer people stay enrolled in an HDHP plan, the more satisfied they become with it:

  • If enrolled in an HDHP for less than one year, just 32% of participants were satisfied with their plan.
  • If enrolled for one to two years, 44% were satisfied.
  • If enrolled three or more years, 55% were satisfied.

Key to HDHP satisfaction

The key to successfully navigating an HDHP comes down to educating yourself in how these plans work, the trade-off between higher out-of-pocket costs and lower premiums, and the importance of taking some of those premium savings and socking them away in a health savings account.

If you have an individual or family HDHP, you can usually qualify to put money into an HSA to fund future health care expenditures.

You can sock away $3,850 (individual account) in 2023 with untaxed income, which you can later use to pay for medical expenses you incur. For a family account, you can save up to $7,750.

HDHPs can look extremely enticing due to their low premiums, but many people jump into them without understanding the potential costs they’ll be paying for out of pocket.

While these plans are required to cover 10 essential services and preventative care, as required by the Affordable Care Act, most other services and medicines are paid for in full at the insurer-contracted rates with providers and pharmacies.

For people who have chronic conditions, and need regular medical care, an HDHP may not be the best plan. But if you are healthier and younger and don’t regularly see the doctor, you can save on your premiums by enrolling in an HDHP.

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Uncategorized

Waiving HDHP Deductibles Has Little Effect on Premiums, Study Says

Employers who offer health savings account-eligible high-deductible health plans (HDHPs) to employees can significantly expand pre-deductible coverage for certain drugs used to manage chronic conditions — with only a tiny effect on premiums.

That’s the finding of a new study from the Employee Benefit Research Institute (EBRI).

The reason: According to research from Johns Hopkins University, poorly managed chronic medical conditions cost employers an estimated $198 billion every year.

These costs show up in several ways:

  • Direct usage of medical services such as preventable ER visits and hospitalization
  • Absenteeism
  • Illness-related presenteeism
  • Cost of temporary workers
  • Overtime costs

Johns Hopkins also estimates employers lose another $178 billion per year in workers’ compensation costs, Family Medical Leave Act costs, and wages and benefits paid during workers’ absence.

The growing cost burden of HDHPs

By 2030, unmanaged chronic diseases such as diabetes, high blood pressure, heart disease, asthma and depression are projected to cost an estimated $2 trillion in direct medical costs, as well as an additional $794 billion in indirect costs like lost employee productivity.

While the combination of health savings accounts (HSAs) and HDHPs was supposed to help reduce costs by encouraging consumers to take more ownership of their own health care, deductibles on important preventative drug therapies cause plan members to skip needed medications.

This has been shown to lead to much more expensive conditions later, including blindness, amputation, heart attacks and strokes.

Conversely, workers and covered family members are significantly more likely to be medication-compliant when these drugs are exempt from their health plan’s deductible — and therefore less likely to be hospitalized, become disabled or need more expensive medical treatment.

Among HDHP plans that expanded pre-deductible coverage to 116 drug classes used to manage expensive long-term, chronic medical conditions, the cost of these drugs was almost entirely offset by reduced health care utilization.

Among the study’s highlights:

  • When plan sponsors allowed plan beneficiaries to access these medications with zero out-of-pocket cost-sharing (e.g., no deductible and no coinsurance), the net impact on premiums was an increase of 4.7%.
  • When employer HDHP plans allowed plan members to access these medications with a coinsurance charge, but no deductible, the direct net effect on premiums was an increase of only 1.3%.

Improved disease management

The EBRI study only measured the direct impact on premiums of expanding pre-deductible coverage to these medications, largely through reduced health care utilization costs, which show up later in the form of higher premiums.

EBRI’s research suggests that employers can realize significant improvements in workforce health and wellness by expanding “first dollar” coverage of certain medications. Helping workers manage their chronic diseases has other powerful positive indirect effects on employers’ bottom lines.

Under current law, HDHP plan sponsors have limited flexibility to cover more than a limited list of 14 medications and services before deductibles are met.

But there are several innovative strategies employers can use to close the coverage gap and encourage employees to get the care they need to prevent them from getting sicker, including HSAs and health reimbursement arrangements.

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How to Coax Your Employees to Enroll in an HDHP

Employers looking for ways to decrease their group health insurance outlays over the past decade have been turning to high-deductible health plans as they offer lower up-front premiums.

In 2021, 51% of the U.S. workforce was enrolled in one of these plans, according to a recent survey by ValuePenguine.com.

But successfully coaxing your employees to choose an HDHP is not always easy. It means getting the deductible amounts right and educating them on how to best use these plans.

Also, while the plans are not for everyone, they can be a good fit for those who do not use their health plans much, are young and in good health. These employees may instead be overpaying for their premiums if they are not in an HDHP with an attached health savings account (HSA).

The key to encouraging your staff to adopt these plans is to first understand why some are reticent about them, how you can overcome their objections and how you can better tailor the plans for them. The following are the main reasons HDHP adoption may be lagging among covered workers.

Lack of education

One of the biggest hurdles to overcome is that many people are shocked to see the amount of the deductible, even as they save money on their premium. And on top of that sky-high deductible, they still have copays.

If you want employees that would be better suited for an HDHP to actually sign up for a plan, you need to take the extra time to:

  • Explain how HDHPs work and that there is a trade-off for high deductibles in exchange for lower up-front premiums.
  • Provide custom, side-by-side medical plan comparison tables and different medical usage scenarios to illustrate which types of individuals are best suited for an HDHP and which ones are not. (This would include scenarios of individuals who may be high health care users who may not be well suited for an HDHP.)
  • Explain how they can funnel what they save in premiums into an HSA so they can save their money for future medical expenses (more on HSAs later).

After covering all of the above, you should encourage your staff to pencil out the math to figure out which plan is right for themselves and their families. They can do this with the usage scenarios you provide. They may need assistance in doing this and you can encourage them to ask questions so they can make the best decision.

Too-high deductibles

While employees expect an HDHP to have a higher-deductible than a traditional plan, they can be shocked by a multi-thousand-dollar deductible. And many employers offer plans that are at the maximum end of the deductible spectrum.

For 2022, the maximum out-of-pocket deductible for an HSA-linked single HDHP is $7,050 and for a family plan the total deductible is $14,100. The minimum deductible for these plans is $1,400 for a single plan and $2,800 for a family plan.

You can work with us to model out multiple plan design scenarios that will help you save money on your group benefits bill while maximizing plan adoption. These models do a good job of explaining possible annual outlays and savings at different premium and deductible levels. 

You’re not contributing to their HSAs

Employers will often fund HSAs with a matching contribution up to a certain dollar amount, but that’s not required under law. As a result, many employers do not contribute to these accounts. But HSAs are critical to the success of HDHPs.

It’s often hard to impart the importance of an HSA and how it can benefit a worker years in the future. To generate interest, it’s a good idea for the employer to offer to contribute to the account if the employee sets up an account. Once an employer starts contributing, the likelihood of the employee starting to do so increases exponentially. 

When selling them on the benefits, explain that an HSA never expires. Your employees can keep them for life and let the funds grow in value through investments, and then put them to use when they are older or if they have health problems years later.

Additionally, they are funded with pre-tax earnings, and withdrawals are not taxed either.

Tell them this is essentially free money and that at some point this year or far in the future, they may need the money in the account to pay for medical services.

The takeaway

Helping your workforce understand how HDHPs (coupled with an HSA) can benefit them is the best way to encourage them to enroll.

You may not convince everyone that an HDHP is right for them, but if you get through to some of the ones who can benefit from an HDHP, they may share their experience with colleagues later.

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2022 HSA Contribution Limits, HDHP Minimums, Maximums Set

The IRS has set the maximum amounts employees can funnel into their health savings accounts and health reimbursement accounts (HRAs) for the 2022 policy year.

The IRS updates these amounts every year to adjust for inflation in addition to minimum deductibles for high-deductible health plans, as well as the out-of-pocket maximums your employees are subject to. HSAs, which help employees save for medical expenses, are only available to employees enrolled in HDHPs. 

Here are the new figures for 2022:

HSA annual contribution limit

  • Individual plan: $3,650, up from $3,600 in 2021
  • Family plan: $7,300, up from $7,200 in 2021

HDHP minimum annual deductible

  • Individual plan: $1,400, the same as in 2021
  • Family plan: $2,800, the same as in 2021

HDHP annual out-of-pocket maximum

  • Individual plan: $7,050, up from $7,000 in 2021
  • Family plan: $14,100, up from $14,000 in 2021

Excepted benefit HRA

  • Maximum annual employer contribution: $1,800, the same as in 2021

Federal law requires health plan enrollees to use HSAs with HDHPs.

HSAs explained

An HSA is a special bank account for your employees’ eligible health care costs. They can put money into their HSA through pre-tax payroll deduction, deposits or transfers. As the amount grows over time, they can continue to save it or spend it on eligible expenses. 

Employers can also contribute to the accounts, but the annual contribution maximum applies to all contributions in total (from the employee and the employer). 

The money in the HSA belongs to the employee and is theirs to keep, even if they switch jobs. The funds roll over from year to year and can earn interest. Some plans also have investment options for the funds.

There are a number of benefits for employees who have HSAs:

  • The money an employee contributes to an HSA is not subject to income taxes.
  • If employees contribute through payroll deduction, the amount is taken from their pay before taxes are taken out, which reduces their overall taxable income.
  • They are not taxed on withdrawals, and HSAs even help reduce taxable income.
  • If employees contribute to their HSA with after-tax money, they can deduct their contributions during tax time on Form 1040.
  • Employees can tap the funds for any approved out-of-pocket medical expenses.

Here’s how they work:

  • Employees can make withdrawals with a debit card or check specific to the HSA.
  • Employees can use the money in their HSA to pay for care until they reach their deductible, out-of-pocket expenses like copays and coinsurance.
  • They can use the funds to pay for other eligible expenses not covered by their HDHP, like dental or vision care (eye exams and corrective lenses).
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Uncategorized

Put Money into an HSA instead of a 401(k) After Employer Matching: Report

One of the main recommendations for employees with 401(k) plans is that they should contribute at least enough to their plan every paycheck to ensure they receive the maximum they can in their employer’s matching contributions.

But a new study by Willis Towers Watson recommends that younger, healthier workers should divert savings to their health savings account from their 401(k) after capping out employer matching instead of continuing to put money into their retirement plan.

The report reasons that if they do this, they can get more bang for their buck when they use their HSAs to pay for future medical expenses.

That’s because HSAs can be kept for life and the money they’ve accumulated in them can be used to pay for medical expenses whenever they need them, including in retirement. And the moneys used in HSAs to pay for those expenses are not taxed when they are withdrawn, unlike 401(k)s, the funds of which are subject to federal income tax when withdrawn

The benefits of HSAs

With HSAs:

  • Pretax contributions, gains from investment, and withdrawals used for qualified medical expenses are exempt from federal and most state taxes.
  • Any unused balance is carried over to the next year.
  • Funds never expire.
  • Unused funds can be passed on to a beneficiary after death.
  • After turning 65, account holders can withdraw money for any purpose. However, if those funds are not use for a bona fide medical expense, they are taxed as income.

No other retirement savings vehicle has the same tax advantages as an HSA, so a dollar saved in an HSA can be worth significantly more than an unmatched dollar saved in a 401(k), according to Willis Towers Watson. Some employers will match a portion of workers’ HSA contributions or seed their accounts with money to encourage participation. 

That said, HSAs won’t outperform funds that are matched partly or fully by an employer, according to the report.

Willis Towers Watson said that those tax-free dollars and withdrawals can help pay for health care when we are likely to use it most: in retirement.

Men who retire at 65 with an average life expectancy of 85 would spend about $140,000 out of pocket for medical costs, and woman who retires at the same age and lives to 87 would spend an average of $159,000, according to the research.

The HSA pitch

HSAs can only be used in conjunction with a high-deductible health plan. When HSAs were first introduced, they did not have investment options for the money in the accounts, but as they have grown in popularity over the years, many HSAs now have evolved to essentially have the same investment choices as a 401(k).

HSAs have rules about how much of the balance can be invested. They will typically require that the first $1,000 in the account to be held in cash, and anything above that can be invested to help the funds grow over time.

In 2021, workers can contribute a maximum of $3,600 to their individual HSA account and $7,200 to a family coverage account.

If you are offering your workers high-deductible health plans with matching HSAs, and if you also provide a 401(k) and match part of the contributions, you may want to consider sharing this information with them to help them make informed choices on where to park their money for future use.

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HDHPs Do Not Slow Down Health Care Spending: Study

A new study has found that high-deductible health plans have only a limited effect on the growth of health care spending for people who sign on for these plans.

The National Bureau of Economic Research researched HDHPs over a period of four years and found they failed to control health spending any more than traditional preferred provider organization plans (PPOs) and health maintenance organizations (HMOs). The only statistically significant impact on lower growth by HDHPs was on more expensive pharmaceuticals.

The news comes as HDHPs continue growing in use and popularity among employers and some of their workers. They are often paired with a health savings account that allows participants to set aside a portion of their wages before taxes in special accounts used to pay for health-related expenses, including deductibles.

When HDHPs first came on the scene they were touted as a potential cost-saver. The logic went that when the worker has more skin in the game and has to pay more for their medical care and medications, they will shop around for the lowest-cost service or drug.

Here are the main findings of the report:

  • Covered workers who switched from low-deductible plans to high-deductible plans saw lower growth rates of spending, but for no more than a year.
  • HDHPs seem to discourage the use of less cost-effective drugs. The report surmised that’s because people with these plans will be more motivated to shop around for better prices, like from an online pharmacy.

Considerations

PPOs continue to be the most popular choice among employees and HDHPs continue growing as employers look to cut their and their employees’ premium expenditures, according to a recent report by Benefitfocus, a benefits technology company. HDHPs currently account for about 30% of group health plans in play.

Also, some employees prefer having an HDHP as they can save money up front on the premium.

Over the past few years, employers have noticed that younger and healthier workers will gravitate towards HDHPs when offered them, as they will usually not need much health care and they are willing to trade a lower up-front premium for the small likelihood that they will need a significant amount of medical care, which they would have to pay for out of pocket.

However, workers in their 40s and older are more apt to stick to their PPO or HMO plans, which have higher premiums but lower out-of-pocket maximums.

But the authors of the National Bureau of Economic Research report said that for some people with health problems, HDHPs “may have high adverse health consequences when patients delay, reduce, or forgo care to curb costs, even when costs are moderate compared to health benefits.”

The takeaway

There is no doubt that HDHPs will continue growing in use, but they are not for everyone. Employers that give their workers an option of choosing an HDHP or a traditional PPO plan will be able to better cater to the different needs of their workers.

This is important as the U.S. workforce becomes more diversified, and for employers with multi-generational employee pools.

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Uncategorized

IRS Allows HDHPs to Pay for COVID-19 Testing, Treatment Pre-Deductible

The IRS has issued new emergency guidance that allows insurers to waive the cost of coronavirus testing and treatment for individuals who are enrolled in high-deductible health plans (HDHPs).

Major health insurers report they’ve been concerned that if they can make the change to their high-deductible plans without breaching IRS regulations regarding such plans. 

Specifically, the new guidance states that HDHPs will not lose their plan status if they provide medical care services and items related to coronavirus testing or treatment even before an enrollee has met their deductible.

While the regulation does not require HDHPs to cover the testing and treatment without any out-of-pocket expenses by the enrollee, the plans can do so ― and without breaching the rules regarding these plans.

The new rule could also pave the way for non-HDHPs like PPOs and HMOs to also provide coronavirus testing without out-of-pocket costs for their participants. While there is no rule preventing them from doing so now, many of the country’s large PPOs and HMOs have been reluctant to start offering free testing until they know how HSA plans would be affected.

Typically, enrollees in HDHPs with an attached HSA are required to pay all of their medicinal costs up to their deductible before the insurer will pay. The Trump administration earlier issued another rule that allows HDHPs to foot the bill for certain preventative health services, such as vaccines and screenings for specific conditions like diabetes and high blood pressure before the deductible is met.

In notice 2020-15, the IRS says that “Due to the unprecedented public health emergency posed by COVID-19, and the need to eliminate potential administrative and financial barriers to testing for and treatment of COVID-19, a health plan that otherwise satisfies the requirements to be an HDHP under section 223(c)(2)(A) will not fail to be an HDHP merely because the health plan provides medical care services and items purchased related to testing for and treatment of COVID-19 prior to the satisfaction of the applicable minimum deductible.”

The notice only applies to coronavirus and does not void any other requirements governing HDHPs and HSAs. It states that “Individuals participating in HDHPs or any other type of health plan should consult their particular health plan regarding the health benefits for testing and treatment of COVID-19 provided by the plan, including the potential application of any deductible or cost-sharing.”

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