ARTICLE
22 November 2024

The Internal Revenue Service Health And Welfare Limits For 2025

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Winston & Strawn LLP

Contributor

Winston & Strawn LLP is an international law firm with 15 offices located throughout North America, Asia, and Europe. More information about the firm is available at www.winston.com.
The Internal Revenue Service recently published limits for 2025 in Revenue Procedure 2024-40. Below we have outlined health and welfare limits for 2025 and the changes in those limits from 2024.
United States Food, Drugs, Healthcare, Life Sciences

The Internal Revenue Service recently published limits for 2025 in Revenue Procedure 2024-40. Below we have outlined health and welfare limits for 2025 and the changes in those limits from 2024.

Account

2024

2025

Change from 2024 to 2025

Health Care Flexible Spending Account

Maximum contribution amount per employee

$3,200

$3,300

Increase of $100

Dependent Care Flexible Spending Account

Maximum contribution amount per individual or married couples filing jointly

$5,000

$5,000

No change

Maximum contribution amount per individual or married couple filing separately

$2,500

$2,500

No change

Adoption Assistance

The amount that can be excluded from an employee's gross income for the adoption of a child with special needs (the amount excludable from an employee's gross income begins to phase out for taxpayers with modified adjusted gross income in excess of $259,190 and is completely phased out for taxpayers with modified adjusted gross income of $299,190 or more)

$16,810

$17,280

Increase of $470

Commuter Benefits

The aggregate fringe benefit exclusion amount for transportation in a commuter highway vehicle, transit pass, and qualified parking

$315 per month

$325 per month

Increase of $10 per month or $120 per year

Consumer-Directed Accounts

High-Deductible Health Plan (HDHP)

HDHP – Minimum annual deductible:

Self-only coverage

$1,600

$1,650

Increase of $50

Family coverage

$3,200

$3,300

Increase of $100

HDHP – Maximum out-of-pocket amounts (this includes deductibles, co-payments and co-insurance, but not premiums)

Self-only coverage

$8,050

$8,300

Increase of $250

Family coverage

$16,100

$16,600

Increase of $500

Health Savings Accounts (HSA)

HSA– Annual contribution limit:

Self-only coverage

$4,150

$4,300

Increase of $150

Family coverage

$8,300

$8,550

Increase of $250

Catch-up contributions (age 55 or older)

$1,000

$1,000

No change

In addition, the Centers for Medicare and Medicaid Services (CMS) recently published their annual guidance regarding the maximum limitation on cost sharing for 2026, including an annual out-of-pocket maximum limit (the Affordable Care Act requires that non-grandfathered health plans comply with cost-sharing limits for essential health benefits). CMS has indicated that the annual out-of-pocket maximum limit for non-grandfathered plans will increase approximately 10.3% as shown in the chart below:

Maximum Out-of-Pocket Limit Under ACA

2025

2026

Change from 2025 to 2026

Self-only coverage

$9,200

$10,150

Increase of $950

Family coverage

$18,400

$20,300

Increase of $1,900

Note: The Internal Revenue Service will publish the 2026 out-of-pocket maximums and other limits for high-deductiblehealth plans in 2025.

Winston Takeaway

Plan sponsors should ensure the increased dollar limits are appropriately reflected in their payroll and plan administration programs for 2025 and included in annual and other required communications to plan participants. Plan sponsors and health insurance issuers of non-grandfathered health plans should also review the recently updated out-of-pocket maximums when addressing their health plan designs and cost-sharing requirements for 2026.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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