Planning Ahead: 2026 HSA Limits Rise & Compliance Deadlines Approaching
- Cottingham & Butler
- May 8
- 2 min read
Stay compliant with the latest healthcare benefit updates, contribution limits, and important filing deadlines for employers.
2026 HSA and HDHP Limits Increase: What Employers Need to Know
On May 1, 2025, the IRS released Revenue Procedure 2025-19, providing the inflation-adjusted limits for Health Savings Accounts (HSAs) and High-Deductible Health Plans (HDHPs) for 2026. These annual adjustments help employees maximize their tax-advantaged healthcare savings.
Key HSA Contribution Increases for 2026
For the upcoming year, employers and employees will benefit from the following increased contribution limits:
Self-only HDHP coverage: HSA contribution limit increases to $4,400 (up $100 from 2025)
Family HDHP coverage: HSA contribution limit rises to $8,750 (up $200 from 2025)
Catch-up contributions: Remains at $1,000 for individuals age 55 and older (not subject to inflation adjustments)
HDHP Plan Design Changes for 2026
Employers sponsoring HDHPs should note these important cost-sharing limit adjustments:
Minimum Deductible Requirements:
Self-only coverage: Increases to $1,700 (up $50 from 2025)
Family coverage: Increases to $3,400 (up $100 from 2025)
Maximum Out-of-Pocket Expense Limits:
Self-only coverage: Rises to $8,500 (up $200 from 2025)
Family coverage: Rises to $17,000 (up $400 from 2025)
Action Item: Employers should review their HDHP cost-sharing limits when preparing for plan years beginning in 2026 and update employee communications with these new contribution limits.
Important Compliance Deadlines Approaching in 2025
RxDC Reports Due by June 1, 2025
The prescription drug data collection (RxDC) reporting deadline is quickly approaching. This mandatory annual filing requires detailed information on prescription drug and healthcare spending for the previous calendar year.
What Employers Need to Know:
Who must file: All group health plans including fully insured, self-insured, and level-funded plans
Deadline: Sunday, June 1, 2025 (covering 2024 data)
Reporting requirements: Plan-level information, enrollment data, premium data, and detailed medical/pharmacy benefit information
Submission process: Reports must be submitted through the CMS online portal
Most employer-sponsored health plans rely on their carriers, TPAs, and PBMs to provide necessary data and often submit reports to CMS on behalf of employer group health plans.
Action Item: Contact your benefits administrator now to ensure your RxDC reporting is on schedule.
Form 5500 Filing Deadline: July 31 for Calendar Year Plans
Employers subject to ERISA must file an annual report (Form 5500) for each employee benefit plan unless a filing exemption applies.
Key Form 5500 Information:
Deadline for calendar year plans: July 31, 2025 (for 2024 plan year)
Extension option: 2.5-month extension available (until October 15, 2025) by filing Form 5558 by July 31
Filing exemption: Small welfare benefit plans (fewer than 100 covered participants) that are unfunded or fully insured
Filing method: Electronic submission through the DOL's EFAST2 system
Action Item: Employers with calendar year plans should begin gathering necessary documentation and work with service providers to ensure timely filing.
Need Assistance with Healthcare Compliance?
Contact your Cottingham & Butler team today for expert guidance on:
Implementing the new HSA/HDHP limits
Preparing your RxDC reports
Completing Form 5500 filings
Obtaining necessary information from carriers/TPAs