Lest we lose sight of upcoming changes attributable to the Affordable Case Act completely, let's recall changes that were made to HSAs. First, remember that after January 1, 2011, over-the-counter medications can only be reimbursed with a prescription. Second, the penalty for non-qualified withdrawals was increased to 20% of the amount of the distribution.

Now, there are some limit changes that have to be addressed in your 2012 plan documentation. On May 16, the IRS issued Rev. Proc. 2011-32 that sets the following limits for HDHPs and HSAs for 2012:

  1. Maximum Annual Contribution to HSAs: $3,100 for single, $6,250 for family
  2. Minimum HDHP Deductible (no change): $1,200 for single, $2,400 for family
  3. Maximum HDHP Out-of-Pocket Expense: $6,050 for single, $12,100 for family

The first and third items represent slight increases over the 2011 figures. So if you have an HDHP with an HSA, take a look at your plan documentation and prepare to make the appropriate changes. And if you are thinking about adding an HDHP option for 2012, make sure to incorporate these limits accordingly.