HDHP Rules For Deductible Carry-Over

Can you have a health savings account carryover with a high deductible health plan? Read on to find out in our latest Q&A.

Question
Our company offers a high deductible health plan (HDHP). Employees electing this plan can also contribute to health savings accounts (HSAs). Are there any rules against the HDHP having a three-month deductible carryover?

Answer
An HSA-compatible HDHP may include a deductible carryover provision—but there are important restrictions. If a plan allows expenses incurred in the final months of one plan year to carry over and count toward the following year’s deductible, then the minimum required deductible must be increased proportionally. This is because the deductible is being accumulated over a longer period of time than the standard 12-month plan year.

For example, the minimum required annual deductible for plan years beginning in 2025 is:

  • $1,650 for self-only coverage

  • $3,300 for family coverage

If your HDHP allows expenses from the final three months of the previous plan year to carry over, the deductible accumulation period becomes 15 months, or 25% longer than 12 months. Therefore, the minimum deductible must also increase by 25%:

  • $2,062.50 for self-only coverage

  • $4,125.00 for family coverage

If your HDHP allowed a six-month deductible carryover, the required deductibles would need to increase by 50%.

This ensures the plan continues to meet IRS requirements for HSA compatibility.

This blog is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.

Kim Harry