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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.

Affordable Care Act (ACA)

	2023	2024	2025
• 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 • $3.47 pppy for plan year ending 10/1/24-12/31/24

Health and/or Limited Purpose Flexible Spending Account (FSA)

	2023	2024	2025
• Max paycheck deductions (employer may also contribute greater of $500 or 1:1 match)	• $3,050/yr	• $3,200/yr	• $3,300/yr
• Max carryover to a plan starting the next CY	• $610 to a 2024 plan	• $640 to a 2025 plan	• $660 to a 2026 plan

Dependent Care FSA

	2023	2024	2025
• 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)

	2023	2024	2025
• 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

	2023	2024	2025
• Qualified parking • Transit passes and vanpools	• $300/mo • $300/mo	• $315/mo • $315/mo	• $325/mo • $325/mo

Non-Discrimination Testing

	2023	2024	2025
• Highly compensated employee (HCE)	• $150,000	• $155,000	• $__
• Key employee	• $215,000	• $220,000	• $__

Other Plans

	2023	2024	2025
• 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 • $6,350 single • $12,800 family • $17,280 • $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.