2025 Indexing of Out-of-Pocket Limits and Affordable Care Act Penalties

Regulators have announced proposed benefit and payment parameters for 2025 which mostly concern the operation of the individual insurance Marketplace.  One interesting proposal includes requiring at least one consumer representative to be part of the pharmacy and therapeutic (P&T) committee that decides which drugs are to be included on a plan’s formulary.

They have also finalized 2025 indexing that impacts employer benefit plans.  Those updates are summarized below.

Non-grandfathered medical plan OOP limits

	2023	2024	2025
Per person	$9,100	$9,450	$9,200
Per family	$18,200	$18,900	$18,400

Applicable large employer ACA penalties

	2023	2024	2025
4980H(a) per month	$2,880/yr $240.00/mo	$2,970/yr $247.50/mo	$2,900/yr ≈$241.67/mo
4980H(b) per month	$4,320/yr $360.00/m	$4,460/yr ≈$371.67/mo	$4,350/yr $362.50/mo

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.