Table of 2025 Indexed Benefit Limits

We are providing a table below of 2025 indexed benefit limits we have seen published so far.

We updated each number below as figures are released throughout the year. HSAs are typically announced in May, affordability is typically announced in August, a host of other limits are typically announced in October, and the FPL for non-calendar year plans is released mid-January 2025.

	2023	2024	2025
Affordable Care Act (ACA)
Affordability % Single FPL for 1/1 plan Single PFL for non-CY plan	9.12% $103.28/mo $110.80/mo	8.39% $101.93/mo $105.29/mo	9.02% $113.20/mo $__/mo
§4980H(a) penalty Per month	$2,880/yr $240.00/mo	$2,970/yr $247.50/mo	$2,900/yr $241.67/mo
§4980H(b) penalty Per month	$4,320/yr $360.00/mo	$4,460/yr $371.67/mo	$4,350/yr $362.50/mo
Non-grandfathered (non-GF) max out-of-pocket (OOP)	Per person $9,100/yr Family $18,200/yr	Per person $9,450/yr Family $18,900/yr	Per person $9,200/yr Family $18,400/yr
Patient Centered Outcomes Research (PCOR) fee (payable by employers with health reimbursement arrangement (HRA) or self-funded health plan)	For PCOR fee due Monday 7/31/23 $2.79 pppy for plan year ending 1/1/22-9/30/22 $3.00 pppy for plan year ending 10/1/22-12/31/22	For PCOR fee due Wednesday 7/31/24 $3.00 pppy for plan year ending 1/1/23-9/30/23 $3.22 pppy for plan year ending 10/1/23-12/31/23	For PCOR fee due Thursday 7/31/25 $3.22 pppy for plan year ending 1/1/24-9/30/24 $__ pppy for plan year ending 10/1/24-12/31/24
Health and/or Limited Purpose Flexible Spending Account (FSA)
Max paycheck deductions (employer may also contribute greater of $500 or 1:1 match)	$3,050/yr	$3,200/yr	estimated $3,300/yr
Max carryover to a plan starting the next CY	$610 to a 2024 plan	$640 to a 2025 plan	estimated $660 to a 2026 plan
Dependent Care FSA
Max contribution (includes both employer and employee* funds; might need to pro-rate down for partial year eligibility)*	$5,000/yr $2,500/yr if married filing separately	$5,000/yr $2,500/yr if married filing separately	$5,000/yr $2,500/yr if married filing separately
Health Savings Account (HSA)
Max contribution (includes both employer and employee* funds; might need to pro-rate down for partial year eligibility)*	Single $3,850/yr Family $7,750/yr	Single $4,150/yr Family $8,300/yr	Single $4,300/yr Family $8,550/yr
Catch-up contribution (per HSA account holder age 55+ on 12/31 that year; never indexes)	$1,000/yr	$1,000/yr	$1,000/yr
HDHP minimum deductible	Single $1,500/yr Family $3,000/yr If non-single coverage offers an embedded per-person deductible, must set that to at least $3,000	Single $1,600/yr Family $3,200/yrI f non-single coverage offers an embedded per-person deductible, must set that to at least $3,200	Single $1,650/yr Family $3,300/yr If non-single coverage offers an embedded per-person deductible, must set that to at least $3,300
HDHP max OOP (if non-GF, note family per-person OOP limit)	Single $7,500/yr Family $15,000/yr Non-GF $9,100 per person	Single $8,050/yr Family $16,100/yr Non-GF $9,450 per person	Single $8,300/yr Family $16,600/yr Non-GF $9,200 per person
§ 132 Qualified Commuter Plan
Qualified parking Transit passes and vanpools	$300/mo $300/mo	$315/mo $315/mo	estimated $325/mo estimated $325/mo
Non-Discrimination Testing
Highly compensated employee (HCE)	$150,000	$155,000	$__
Key employee	$215,000	$220,000	$__
Other Plans
Excepted benefit HRA Qualified small employer HRA Adoption assistance §137 Education assistance §127 (can include student loans 2020 through end of 2025)*	$1,950 $5,850 single $11,800 family $15,950 $5,250*	$2,100 $6,150 single $12,450 family $16,810 $5,250*	$2,150 $__ single $__ family $__ $5,250*

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

Table of 2025 Indexed Benefit Limits

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