IRS Releases 2027 HSA, HDHP, and EBHRA Limits

As a reminder for employers and plan sponsors, the Internal Revenue Service (IRS) announced the inflation-adjusted limits for Health Savings Accounts (HSAs), High-Deductible Health Plans (HDHPs), Excepted Benefit Health Reimbursement Arrangements (EBHRAs), and Direct Primary Care Service Arrangements (DPCSAs) for the 2027 plan year.

The updates reflect modest increases from prior years and include new HSA-compatibility rules for qualifying DPCSAs, following changes made by the One Big Beautiful Bill Act (OBBBA). The IRS released these figures earlier than usual, giving employers time to update payroll systems, plan designs, and enrollment materials ahead of the 2027 open enrollment cycle.

This update applies to employers sponsoring HDHPs, HSAs, EBHRAs, or DPCSAs. The limits apply to plan years beginning in 2027.

What Employers Should Do

Legal Requirements

• Ensure that any HDHP the organization sponsors satisfy the 2027 HSA-qualification thresholds: at least $1,750 minimum deductible (self-only) or $3,500 (family), and no more than $8,700 (self-only) or $17,400 (family) in out-of-pocket expenses.
• If offering an EBHRA, do not make more than $2,250 available to any employee for plan years beginning in 2027.
• If offering a qualifying DPCSA, keep monthly fees at or below $150 (individual) or $300 (covering more than one person) so that employees enrolled in both the DPCSA and an HDHP remain eligible to contribute to an HSA.

Practical Considerations

• Update payroll systems and HSA contribution defaults to reflect the new 2027 limits ($4,500 self-only, $9,000 family, plus the $1,000 catch-up for employees age 55 or older), and update open enrollment materials, benefit guides, summary plan descriptions, and employee communications to match.
• Coordinate with insurance carriers, HSA custodians, and third-party administrators (TPAs) to confirm that HDHP plan designs satisfy the 2027 thresholds and that their systems are ready to accept the new contribution amounts by the first payroll of the 2027 plan year.
• Consider engaging a Professional Employer Organization (PEO) or Administrative Services Organization (ASO) to help manage the payroll updates, plan design reviews, and employee communications tied to the annual IRS adjustments.

Overview

2027 IRS Limits

Category	2025	2026	2027
HSA Contribution Limit – Self-only	$4,300	$4,400	$4,500
HSA Contribution Limit – Family	$8,550	$8,750	$9,000
Catch-up Contribution (age 55+)	$1,000	$1,000	$1,000
HDHP Minimum Deductible – Self-only	$1,650	$1,700	$1,750
HDHP Minimum Deductible – Family	$3,300	$3,400	$3,500
HDHP Out-of-Pocket Max – Self-only	$8,300	$8,500	$8,700
HDHP Out-of-Pocket Max – Family	$16,600	$17,000	$17,400
EBHRA Maximum Amount	$2,150	$2,200	$2,250
DPCSA Monthly Limit – Individual	N/A	N/A	$150
DPCSA Monthly Limit – Family (2+)	N/A	N/A	$300

Note: The catch-up contribution amount is fixed by statute and does not adjust for inflation. DPCSA HSA-compatibility limits are new for 2027 following OBBBA.

Why This Matters

The 2027 IRS limits raise HSA contribution amounts, adjust the thresholds high-deductible plans must meet to remain HSA-compatible, and confirm that certain direct primary care arrangements no longer block HSA eligibility.

HSAs remain highly tax-advantaged: contributions are generally not taxed, grow tax-free, and can be withdrawn tax-free for qualified medical expenses.

Key Risks for Employers

• If the employer’s high-deductible plan does not meet the 2027 deductible or out-of-pocket thresholds, it stops being an HSA-qualified plan. That means enrolled employees cannot make or receive HSA contributions for those months, and HSA contributions made for an ineligible individual may become taxable and may require correction.

• If the employer makes more than $2,250 available under an EBHRA, the arrangement may lose its “excepted benefit” status and become subject to the broader ACA and Employee Retirement Income Security Act (ERISA) requirements it was designed to avoid.

Additional Information

The One Big Beautiful Bill Act (OBBBA) amended the tax code so that certain DPCSAs are no longer treated as disqualifying health coverage for HSA purposes.

Under the new rule, an employee can enroll in both a high-deductible plan and a qualifying direct primary care arrangement and still contribute to an HSA, as long as the direct primary care monthly fees stay within the IRS limits ($150 for individual coverage, $300 for coverage of more than one person). If the fees exceed those amounts, the employee loses HSA eligibility for that month. There is no partial relief.

Separately, the IRS confirmed that the Affordable Care Act (ACA) out-of-pocket maximums for most employer-sponsored health plans are different from and typically higher than the HDHP out-of-pocket maximums that apply for HSA eligibility. Employers should track both, since they apply for different purposes. The official source is IRS Revenue Procedure 2026-24.

Source References

• IRS – Revenue Procedure 2026-24 (June 15, 2026)
• IRS – Revenue Procedure 2026-24
• Reminder Federal: IRS Announces 2026 Limits for HSAs, HDHPs, and ACA Out-of-Pocket Maximums (VensureHR)

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