The 2026 HSA Contribution Limits

Executive Summary 
The IRS has issued its annual inflation adjustment to the HSA contribution limits for 2026: 

• Individual Coverage: $4,400 ($100 increase) 

• Family Coverage: $8,750 ($200 increase) 

2026 Inflation Adjusted Amounts for HSAs and HDHPs 
The IRS issues annual updates by June 1 announcing the HSA contribution limit increases for the following year. The cost-of-living adjustments are based on the Chained Consumer Price Index for All Urban Consumers (C-CPI-U). HSA contribution limits are based on the calendar year. They are not related to the high deductible health plan (HDHP) plan year.    

The full guidance for the 2026 HSA limit increases is available here:  

• IRS Revenue Procedure 2025-19 

The much higher-than-normal inflation from 2022 (7%-8%) decreased significantly in 2023 and has settled at levels around 2-3% since mid-2023.  The abnormally large HSA contributions increases we saw for 2024  ($300/$550) therefore settled down in similar manner to more normal increases for 2025 and 2026.  The result is a $100 and $200 increase to the 2026 individual and family HSA contribution limits, respectively.  

The 2026 calendar year HSA contribution limits are as follows: 

• The 2026 HSA contribution limit for individual coverage increases by $100 to $4,400. 

• The 2026 HSA contribution limit for family coverage (employee plus at least one other covered individual) increases by $200 to $8,750. 

Note: The age 55+ catch-up contribution limit of $1,000 is fixed by law and does not adjust for inflation.  

The annual IRS update also includes the 2026 calendar year minimum deductible and out-of-pocket maximums allowed for a plan to qualify as a §223 HSA-compatible high deductible health plan (HDHP), which is the required coverage for an individual to be eligible to make or receive HSA contributions.     

The 2026 HDHP inflation adjusted amounts are as follows: 

• The 2026 minimum deductible for individual coverage increases by $50 to $1,700. 

• The 2026 minimum deductible for family coverage increases by $100 to $3,400. 

• The 2026 maximum out-of-pocket limit for individual coverage increases by $200 to $8,500. 

• The 2026 maximum out-of-pocket limit for family coverage will increase by $400 to $17,000. 

Note: For the family HDHP coverage tier, any embedded individual deductible cannot be lower than the minimum family coverage deductible ($3,400 in 2026).  

The Basics: Understanding HSAs 
Health Savings Account (HSA) eligibility is required for any individual to establish an account and make or receive HSA contributions.  Individuals must satisfy the following four requirements to be HSA-eligible: 

1. Be covered by a qualified high deductible health plan (HDHP); 

2. Have no other disqualifying health coverage; 

3. Not be enrolled in any part of Medicare; and 

4. Not be able to be claimed as a dependent on someone else’s current-year tax return. 

Employees can take a tax-free distribution from their HSA to pay or be reimbursed for IRC §213(d) qualified medical expenses that are incurred after establishing the account and are not reimbursed by another plan or arrangement.  The IRS overview of what constitutes a §213(d) medical expense is IRS Publication 502.   

For more details: 

• The HSA Eligibility Requirements: Part I 

• The HSA Eligibility Requirements: Part II 

• The HSA Contribution Rules: Part I 

• The HSA Contribution Rules: Part II 

• The HSA Distribution Rules: Part I 

• The HSA Distribution Rules Part II 

• Newfront Go All the Way With HSA Guide 

HSA Reminders: Recent Changes 
A number of important changes have occurred for HSAs in recent months:  

HDHP Preventive Care Expanded to More Contraceptives 

In the recently released IRS Notice 2024-75, the IRS added two types of contraception to the list of preventive care that HDHPs can cover before satisfaction of the deductible: 

1. Over-the-Counter Oral Contraceptives 

2. Male Condoms 

The guidance also added new clarifications on the scope of three existing types of preventive services that HDHPs can cover before the individual satisfies the deductible: 

1. Breast Cancer Screening 

2. Continuous Glucose Monitors 

3. Selected Insulin Products 

Not all HDHPs will cover the expenses addressed in this new IRS guidance, and not all these expenses that are covered will be available prior to satisfaction of the HDHP deductible. Employers should consult with their insurance carrier/TPA to coordinate which of these newly available/clarified preventive services the plan incorporates with first-dollar coverage (or coverage not otherwise subject to the deductible).  

• For more details: HDHP Preventive Care Expanded to More Contraceptives 

First-Dollar Telehealth Coverage Expiration for Plan Years Beginning On or After January 1, 2025 
The CARES Act, CAA 2022, and CAA 2023 all provided relief in light of the pandemic from the minimum deductible requirement for telehealth and other remote care services—regardless of whether such services were preventive.  Those legislative packages allowed individuals to maintain HSA eligibility even where their HDHPs waives the deductible for any telehealth or other remote care.  

This telehealth relief only extended to plan years beginning before January 1, 2025.  Accordingly, for plan years beginning in 2025 (including 2025 calendar plan years), HDHPs now must resume imposing the standard minimum statutory deductible for telehealth and other remote care services in order for covered participants to maintain their HSA eligibility. 

• Note: The original draft of the government funding bill at the end of 2024 would have extended telehealth relief through 2026.  After severe public backlash to the size and scope of the bill, a much skinnier version passed that did not include the HSA telehealth relief extension.  

First-Dollar Covid Testing/Treatment Expiration for Plan Years Ending On or After January 1, 2025 
IRS relief since the start of the pandemic had permitted HDHPs to waive the deductible and provide first-dollar coverage for medical care services and items related to testing and treatment of Covid.  The IRS provided the relief to “eliminate potential administrative and financial barriers to testing for and treatment of COVD-19.”  

IRS guidance confirms that this relief is no longer available, as it applied only for plan years ending on or before December 31, 2024.  Accordingly, HDHPs now must impose the standard minimum deductible for Covid testing and treatment in order for covered participants to maintain their HSA eligibility.  

HSA Potential Changes: Possible Legislative Attempts by Republican Congress 
During the first term of President Trump, the ACA repeal/replace efforts (ultimately unsuccessful) attempted to make significant changes to HSAs.  Most significantly, the proposals at the time sought to roughly double the HSA contribution limits and permit tax-free distributions for premiums.  Recent legislation introduced by the new Republican Congress follows a similar path.  Nonetheless, as we learned from the failed ACA repeal/replace efforts in 2017, any such efforts will face significant hurdles to reaching the President’s desk.  

For more details: 

• Potential Employee Benefits Changes in Second Trump Term 

• Newfront Office Hours Webinar: Year in Review 

 For more details on everything HDHP/HSA, see our Newfront Go All the Way With HSA Guide.   

Disclaimer: The intent of this analysis is to provide the recipient with general information regarding the status of, and/or potential concerns related to, the recipient’s current employee benefits issues. This analysis does not necessarily fully address the recipient’s specific issue, and it should not be construed as, nor is it intended to provide, legal advice. Furthermore, this message does not establish an attorney-client relationship.  Questions regarding specific issues should be addressed to the person(s) who provide legal advice to the recipient regarding employee benefits issues (e.g., the recipient’s general counsel or an attorney hired by the recipient who specializes in employee benefits law).