Before changing a deduction in payroll, ask which limit the number represents. An HSA contribution ceiling, a health-plan deductible, a DPC fee threshold, and an employer HRA allocation do different jobs. A table is useful only when those labels stay attached.

The authority and the dates

The source is Revenue Procedure 2026-24, published in Internal Revenue Bulletin 2026-25, dated June 15, 2026, at page 1582. Sections 3–4 provide the amounts and applicability periods. This is a planning explainer of previously issued guidance, not a new November announcement.

This article uses the verified June 15, 2026 bulletin date. It does not assume that a download-directory timestamp establishes an earlier legal release date. The revenue procedure itself supplies the amounts and their applicability. Read the original three-page procedure.

2026 and 2027: compare like with like

Sources: Rev. Proc. 2025-19, section 2 for 2026 HSA/HDHP/HRA amounts; IRC §223(c)(1)(E) for the initial DPC thresholds; and Rev. Proc. 2026-24, section 3 for 2027. HSA amounts are base limits, not a determination of each individual’s permitted contribution. Out-of-pocket figures exclude premiums. The HDHP rows concern the general definition, not every statutory exception.

The dates follow three different rules

Section 4 applies the HSA amounts to calendar year 2027, the DPC thresholds to months beginning in 2027, and the excepted-benefit HRA amount to plan years beginning in 2027. Rev. Proc. 2026-24, section 4.

Hypothetical: an excepted-benefit HRA plan year beginning July 1, 2026 uses the $2,200 limit for amounts newly made available for that plan year. January 1, 2027 does not by itself change that ongoing plan year’s limit. The $2,250 limit applies to its plan year beginning July 1, 2027. This example follows the two procedures’ plan-year wording; it is not an IRS example. 2026 applicability · 2027 applicability.

Payroll needs the employee’s remaining room, not just the headline limit

Employer HSA contributions and employee contributions must be considered together. Eligibility changes, other coverage, Medicare enrollment, and the rules for married individuals can affect the result. Publication 969 explains these mechanics; its older-year numerical examples should not replace the 2027 procedure. Publication 969, Contributions to an HSA.

Hypothetical: assume full-year self-only eligibility, no catch-up contribution, no other HSA contributions, and $1,200 of employer HSA funding for 2027. The remaining base contribution room is $3,300: $4,500 minus $1,200. This is an arithmetic illustration, not a universal payroll election.

The separate age-55 catch-up amount is $1,000 for an otherwise eligible individual; it is not included in the table’s base limits. Each qualifying spouse’s catch-up belongs in that spouse’s own HSA. Do not assume that every employee age 55 or older can contribute without checking eligibility. IRC §223(b)(3) and Publication 969, Additional contribution and Rules for married people.

An excepted-benefit HRA limit is not a limit for every HRA

The $2,250 figure concerns amounts newly available for an excepted-benefit HRA plan year beginning in 2027. It is not a general allowance for all HRAs, health FSAs, or SIMERP cash payments. The governing regulation also requires other qualifying group coverage to be offered, restricts reimbursement of certain premiums, and requires uniform availability to similarly situated individuals. 26 CFR §54.9831-1(c)(3)(viii).

Permitted carryovers are disregarded for this new-allocation limit, while aggregation rules can apply to multiple arrangements. A plan below the dollar cap must still satisfy the other requirements. An excepted-benefit label also does not automatically make the arrangement compatible with HSA contributions. 26 CFR §54.9831-1(c)(3)(viii)(B) and Publication 969, Other employee health plans.

Do not turn the DPC threshold into an HSA reimbursement cap

The DPC fee threshold serves the contribution-eligibility exception. Notice 2026-5 separately explains that an otherwise qualifying DPC fee exceeding that threshold may be reimbursable from existing HSA funds even though enrollment prevents new HSA contributions. It also excludes the employer-paid fees described in Q&A 18 from HSA reimbursement. Notice 2026-5, Q&As 18 and 20.

Read the companion direct-primary-care, HSA, and pretax-payroll explainer for the funding and contract distinctions.

A practical implementation check

SIMERPU recommends reviewing four records together: the benefit schedule, the plan-year calendar, the employer contribution policy, and the payroll election/configuration report. Ask the responsible benefits and payroll teams to reconcile each amount to its source and applicable period.

Use test cases rather than a single maximum contribution: full-year self-only coverage, family coverage, a midyear change, and a participant with employer funding. Ask the adviser responsible for HSA eligibility to address other coverage rather than relying on the name of the medical plan alone. These are review recommendations, not additional legal requirements created by the revenue procedure.

SIMERPU’s assessment

The most useful renewal conversation is not “the numbers went up.” It is “these are the numbers that apply to this arrangement, these are the dates, and this is how we checked the setup.” Keep contribution limits, coverage requirements, expense reimbursement, and wellness cash payments separate. A new annual amount does not approve a broader program design.

Mardy Gould’s Take

Commentary by Mardy Gould, Co-Founder of SIMERPU.

I would rather see one accurate worksheet than a presentation full of bigger numbers. Tell me which account we are discussing, who is funding it, and when the change applies. Then show me that the employee communication and payroll setup say the same thing. That is what would make this update useful to an employer.

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