HSA deductible change to impact grandfathered and transitional relief plans in 2023

The Internal Revenue Service (IRS) has increased the minimum deductible for qualified High Deductible Health Plans (HDHPs) eligible for a health savings account (HSA) to $1,500/$3,000 for individual/family deductibles or $3,000 for an embedded deductible.

UnitedHealthcare’s plans will change to comply with these new deductible limits as follows:

• Most plans will make the change on their renewal in 2023
• Grandfathered and Transitional Relief plans will be changed on Jan. 1, 2023. This will ensure compliance with IRS standard going forward

All Grandfathered and Transitional Relief plans for Small Business customers (2–50) will receive a standalone notice. While this change affects Transitional Relief HSA plans in the 2–50 segment, the same notice and required change will also be made if the plan code is shared by a 51+ plan.

By changing the deductible to meet the IRS limits, UnitedHealthcare is technically making a change to Grandfathered and Transitional Relief plans. Therefore, the change will be handled as a uniform modification (UM) and the current plan names will be kept for the Grandfathered and Transitional Relief plans to renew correctly.

Upcoming communications

• Letter to Grandfathered and Transitional Relief customers: A letter will be sent on Oct. 1 to all Grandfathered and Transitional Relief groups renewing Dec. 1, 2022, through Nov. 1, 2023, communicating the 2023 HSA deductible change. By changing the deductible, these HSA plans will be compliant with IRS requirements and will be able to maintain their tax advantaged status. 
  • The mailing will meet the 60-day requirement before Dec. 1, 2022, consistent with the federal rule
  • For Grandfathered and Transitional Relief plans, all plan codes that have deductible levels under $1,500 or $3,000 should be changed at the same time, regardless of renewal date
• Affordable Care Act (ACA) plans change on 2023 renewal: For groups already on ACA plans, UnitedHealthcare will use the standard renewal package/uniform modification form letter process to inform groups of the HSA change.

For more information, please contact your UnitedHealthcare representative.