2025 Health FSA Limit Increases to $3,300

By Brian Gilmore
October 22, 2024 - NEWFRONT

The IRS has released Revenue Procedure 2024-40 confirming that for plan years beginning on or after January 1, 2025, the health FSA salary reduction contribution limit increases to $3,300.

The adjustment for 2025 represents a $100 increase to the $3,200 health FSA salary reduction contribution limit for 2024.

The contribution limit is set by the ACA (originally $2,500) and adjusts in $50 increments based on a complex cost-of-living calculation tied to consumer price index increases. The inflation levels in 2024 were sufficient to boost the health FSA salary reduction contribution limit by two $50 increments ($100 total) to $3,300 for plan years beginning on or after January 1, 2025.

What About the Carryover Limit into 2025?
The indexed carryover limit for plan years starting in calendar year 2025 to a new plan year starting in calendar year 2026 increases to $660.

The $500 carryover limit is indexed at 20% of the maximum health FSA salary reduction contribution for the plan year. The indexed carryover limit increases in multiples of $10. The adjustment to $660 (20% of the $3,300 limit) for amounts carried into 2026 represents a $20 increase to the $640 carryover limit in effect for amounts carried into 2025.

What About Employer Health FSA Contributions?
As a reminder, employer contributions (including non-cashable flex credits) generally cannot exceed $500 per plan year for the health FSA to maintain excepted benefit status (absent a dollar-for-dollar matching structure). Non-excepted health FSAs generally cannot comply with the ACA market reform mandates.

Therefore, in most cases the maximum health FSA amount available for plan years beginning on or after January 1, 2025 is limited to $3,300 (max employee salary contribution) + $500 (max employer contribution, if offered) = $3,800 (combined).

Also, keep in mind that the health FSA eligibility cannot be broader than the major medical plan eligibility to maintain excepted benefit status (as required by the ACA). In other words, employers cannot offer the health FSA to an employee who is not eligible for the major medical plan (regardless of enrollment).

Other Notable 2025 Health and Welfare Employee Benefit Amounts

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).