News from the Blues

Oct. 1, 2025

Reminder: IRS Inflation Adjustments for 2026 HDHPs and HSAs
Applies to all groups, Individual & Family Markets

As communicated previously, the IRS announced the inflation adjustments for 2026 High Deductible Health Plans and Health Savings Accounts. These adjustments apply for calendar year 2026.

• For calendar year 2026, the annual limit on contributions to an HSA for an individual with self-only coverage under an HDHP is $4,400.
• The annual limit on contributions to an HSA for an individual with family coverage under an HDHP is $8,750.
• The catch-up contribution limit to an HSA (for individuals 55+) is $1,000 (no change from 2025).

High-Deductible Health Plans
For 2026, an HDHP is defined under Section 223(c)(2)(A) of the Internal Revenue Code as a health plan with an annual deductible of at least $1,700 for self-only coverage or $3,400 for family coverage. The annual out-of-pocket (OOP) expenses cannot exceed $8,500 for self-only coverage or $17,000 for family coverage.

• HDHPs with an embedded (or per person) deductible for family coverage have individual deductibles for each person covered, which must be met before benefits are paid for that person. To remain HSA-qualified, the embedded (or per person) deductible can’t be less than the statutory minimum annual deductible for family coverage.

• As a result, HDHPs with an embedded deductible plan design cannot have an individual deductible that is less than the family minimum ($3,400) unless there are separate benefit agreements for employee-only and family HDHP coverage.

IRS 2026/2025 HDHP/HSA Limits: For additional reference, see the IRS bulletin. 

ACA 2026/2025 Limits
Please note that the HDHP limits on out-of-pocket expenses and the maximum out-of-pocket limits under the Affordable Care Act are NOT the same. The ACA maximum out-of-pocket limits for 2026 are:

Extended Renewals & Calendar Year Updates
HDHP plans that have renewals for periods exceeding 12 months must comply with the annual IRS limit changes. For those plans with extended renewals, we will adjust the plan limits to align with IRS changes at the 12-month mark to stay compliant with IRS rules. Applicable account rates and member premium changes will also update after 12 months.