IRS Announces 2024 Health FSA Maximum
November 13, 2023
On November 9, 2023, the Internal Revenue Service (IRS) announced the health flexible spending account (FSA) maximum for 2024 as part of Revenue Procedure 2023-34. As anticipated, the maximum employee contribution to health FSAs will be $3,200 for taxable years beginning in 2024, up $150 from 2023.
Employer contributions to health FSAs that are non-elective, such as matching contributions or flex credits, typically don't factor into the contribution limit. Nevertheless, employers should be careful not to overcontribute to employees' health FSAs, as this could risk the FSA losing its status as an excepted benefit. It's important to be aware that if employees have the option to receive employer contributions as cash or a taxable benefit, these contributions will be treated as salary reductions and will count toward the limit.
Health FSA plans are permitted to offer either a grace period or a carryover feature – but not both. Neither of these features affect the maximum employee salary reduction.
A grace period gives an employee an additional two months and 15 days, immediately following the end of a plan year, to incur new expenses. Any amounts remaining at the end of the grace period must be forfeited. Amounts carried over into the grace period do not count toward the annual limit applicable to the following plan year.
The carryover feature allows employees to roll over up to 20% of the maximum salary reduction contribution for that year. Therefore, the maximum that can be carried over to 2025 will be $640 ($3,200 x 20% = $640). The maximum amount that can be carried over from 2023 to 2024 is $610, based on the 2023 maximum contribution of $3,050 ($3,050 x 20% = $610).
Such a carryover does not affect the limit on salary reduction contributions. This means the plan may allow the individual to elect up to $3,200 in salary reductions for 2024 in addition to the $610 that may be carried over from 2023.
Employers are not required to adopt the IRS health FSA maximum and may instead adopt a different maximum limit for the plan year, as long as it does not exceed the IRS’s maximum limit. For example, an employer could set its health FSA limit at $2,500 or $3,000. All employers should look at what is stated in their plan materials and determine whether an amendment is required.
The above information does not constitute advice. Always contact your employee benefits broker or trusted adviser for insurance-related questions.
EB Compliance Practice Leader
Holly leads Hylant’s ongoing efforts to provide our clients with exceptional compliance consulting services on new developments as well as ongoing requirements affecting health and welfare plans. She has a deep understanding of federal and state regulations pertaining to employee benefit plans, as well as extensive experience in group benefit plan operation.
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