Spring has brought some activity in the health and welfare plan area that affects health savings accounts (HSAs), health plans, and cafeteria plans.
2024 HSA and High-Deductible Health Plan (HDHP) Limits. Revenue Procedure 2023-23 was issued at the end of May, announcing various limits that affect HSAs for 2024:
Annual HSA Contribution Limit
Self-Only $4,150
($300 increase)
Family $8,300
($550 increase)
HSA Catch-Up Contributions
$1,000
(no change)
Minimum Annual HDHP Deductible
Self-Only $1,600
($100 increase)
Family $3,200
($200 increase)
2024 Maximum Amount Available Under an Excepted Benefit Health Reimbursement Arrangement. Rev. Proc. 2023-23 also announced the maximum amount that can be made available under an excepted benefit HRA for 2024 is $2,100 ($150 increase).
Flexible Spending Account Claim Substantiation. Employers and vendors who administer health care or dependent care expense flexible spending accounts, know the headache of substantiating all of those claims. But the IRS is here to tell you to stop taking short-cuts. Specifically, Chief Counsel Memorandum 202317020 released on April 28, 2023 concludes that all claims must be substantiated, and the following “alternative methods” are not sufficient:
- Reliance on self-certification by the participant
- Requiring substantiation of only a random sampling of claims
- Not requiring substantiation of claims under a certain amount
- Not requiring substantiation of claims incurred at certain favored provider
- Accepting advance substantiation of dependent care expenses prior to services being rendered without further verification
This means it’s a good time to review the claims substantiation procedures being used internally or by a vendor.
If you have any questions about how these developments affect your plans, please contact us and we would be happy to get you the answers you need.