In May 2017, the Internal Revenue Service (“IRS”) issued Revenue Procedure 2017-37, which set the 2018 limit at $6,900 for annual contributions made to a health savings account (“HSA”) by those with eligible family health insurance coverage. In March 2018, the IRS issued Internal Revenue Bulletin No. 2018-10, which lowered the 2018 limit by $50, to $6,850, as a result of a change in the inflation-adjustment calculations under the Tax Cuts and Jobs Act. This resulted in many plan sponsors needing to communicate the changes to employees participating in an HSA, to make changes to contributions as necessary, and to alter their payroll systems to account for the new limit.

Now, in Revenue Procedure 2018-27, the IRS rolled back its March 2018 guidance and reinstated the $6,900 limit, as a result of “numerous unanticipated administrative and financial burdens.” Those participating in an HSA are permitted to adjust their contributions in accordance with the again-revised limit. To the extent an individual with an HSA had already contributed the full $6,900 and as a result of the March 2018 guidance had to withdraw the $50 difference, with earnings, that individual can put that money back into the HSA provided it is permitted by the HSA custodian, and should check with the custodian.

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