2017 FSA Contribution Limit Rises to $2,600

2017 limits for commuting, adoption and other benefits also announced

Stephen Miller, CEBS By Stephen Miller, CEBS November 1, 2016
2017 FSA Contribution Limit Rises to $2,600

Update: 2018 FSA Employee Contribution Limit is $2,650

Beginning in 2018, the dollar limit on voluntary employee salary reductions for contributions to health flexible spending arrangements (health FSAs) will be $2,650, up $50 from the 2017 limit of $2,600, the IRS announced in Revenue Procedure 2017-58, issued on Oct. 19, 2017. See the SHRM Online article 2018 FSA Employee Contribution Cap Rises to $2,650.

Employees can put more income into their health care flexible spending accounts in 2017, when the health FSA contribution limit is $2,600.

Other inflation-adjusted benefits caps were also issued by the IRS on the cusp of open-enrollment season for many U.S. companies. Revenue Procedure 2016-55, released on Oct. 25, 2016, includes 2017 dollar limits for qualified transportation benefits and for adoption assistance programs, among others.

The increase in the cost-of-living index—up 1.09 percent between the third quarters of 2015 and 2016—was enough to meet the statutory thresholds that trigger rate adjustments for some employee benefits, but not for others.

Health FSAs

The 2017 limit on voluntary employee salary reductions for contributions to health FSAs is rising to $2,600. Employers should communicate the higher cap to employees during open enrollment and include the new limit in their open-enrollment materials—even if they must, at this late date, do so through a printed or online addendum.

Health FSA Contributions 2017 2016  
Pretax dollar limit$2,600$2,550 

Employer contributions. Health FSAs can be funded on a pretax basis by employees, employers or both. The $2,600 limit applies to employee salary deferral contributions. Employer contributions to an employee’s health FSA may be made in addition to the $2,600 allowed for employee contributions. But according to an analysis by Parker, Smith & Feek, an insurance and risk management brokerage firm with offices in the Pacific Northwest, “although there isn’t technically an annual limitation on employer contributions, health care reform limits employer contributions to $500/year or an arrangement in which the employer contribution will not exceed the employee’s contribution, such as an employer match of employee contributions (up to $2,600).” 

In other words, an employer could either provide a matching contribution or limit its annual account contribution to $500, as the law now stands.

Unspent funds. Since 2013, there have been two options for handling unused funds in a health FSA at year-end that employers can adopt:

  • If a health FSA plan has a carryover feature, participants can roll over up to $500 of unused FSA dollars to the next year but will forfeit any excess over $500 at year-end. Any allowable amount that rolls over into the new plan year will not affect the maximum election that employees can make.

  • Alternatively, an optional grace period can give employees an additional two-and-a-half months—through March 15—to incur new expenses using prior-year FSA funds. At the end of the grace period, all unspent funds must be forfeited to the employer.

Plans can offer either the carryover option or a grace period, but not both, or they can offer neither. 

[SHRM members-only toolkit: Designing and Managing Flexible Benefits (Cafeteria) Plans]

Differences with HSAs. During open enrollment, employees are often confused about the differences between health FSAs and health savings accounts (HSAs), which have higher annual contribution limits and allow unused funds to remain and grow within the account from year to year, among other distinctions. When both FSAs and HSAs are benefit options, open-enrollment communications should clearly state how the two differ, using a side-by-side list of account features, for instance. 

An individual who is covered by a general-purpose health FSA is not eligible to contribute to an HSA. This hold true even if the individual is covered by a health FSA sponsored by a spouse's employer. However, an individual may contribute to both an HSA and a limited-purpose FSA that only may be used for dental and vision-care expenses. 

Plan documents. Finally, some health FSA plan documents reference a hard-dollar maximum figure, making a plan amendment necessary to increase the dollar limit for future years. A better approach, benefit consultants advise, is for plan documents to define the contribution limit as the annual amount allowed by the IRS for the plan year, so that annual amendments are not necessary to permit contributions up to the adjusted pretax limit.

Dependent Care FSAs

A dependent care FSA is a pretax benefit account used to pay for dependent care services such as day care, preschool, summer camps and nonemployer sponsored before or after school programs. It can also be used for elder daycare—when an elderly or disabled parent is considered a dependent and the dependent care account holder is covering more than 50 percent of the elderly or disabled parent's maintenance costs.

The annual contribution limit for a dependent Care FSA is based on the account holder's tax filing status. Generally, joint filers have double the limit of single or separate filers. However, even if each spouse has access to a separate FSA through his or her employer, they are still subject to the mandated maximum limits.

The dependent care FSA maximum is set by statute and is not subject to inflation-related adjustments. These limits have not been raised in several years.

Dependent Care FSA Pretax Contribution Limits 2017 2016  
Account holder is married and files a separate tax return
Account holder is married and files a joint tax return (family maximum) or files as single/head of household

In addition, maximum contributions to a dependent FSA may not exceed these earned income limits:

  • For single account holders, the earned income limit is their salary excluding contributions to their dependent care FSA.

  • For married account holders, the earned income limit is the lesser of their salary excluding contributions to their dependent care FSA or their spouse's salary.

Qualified Transportation Benefits

The monthly dollar limits under section 132(f) for tax-excludable transit and parking benefits, for tax years beginning in 2017, remain unchanged from 2016.

Transit Benefits 2017 2016  
Commuter highway vehicle and transit-pass $255$255 
Qualified parking$255$255 

Long-sought equalization between tax breaks for employer-provided parking and mass-transit benefits was enacted at the end of 2015.

Related: 2017 Transit and Parking Benefits: Design Programs to Increase Workers’ Engagement.

Adoption Assistance Programs

For qualified adoption assistance programs, the maximum amount excludable from federal income tax withholding in 2017 for reimbursements related to the adoption of a child, limited to necessary and reasonable expenses, is shown below. The excludable amount phases out for taxpayers with modified adjusted gross income that exceeds certain levels:

Adoption Benefits 2017 2016
Excludable amount$13,570$13,460
Phase-out income thresholds  
phase-out begins$203,540$201,920
Phase-out complete$243,540$241,920

[SHRM members-only toolkit: Managing Adoption Assistance Benefits]

Long-Term Care Premiums

The IRS allows individuals to deduct qualified medical expenses that exceed 10 percent of their adjusted gross income for the year. Increases in the limits under tax code Section 213 for eligible long-term care premiums that are deductible in 2017—to the extent that they, along with other unreimbursed medical expenses, exceed 10 percent of the insured's adjusted gross income—are shown below, based on attained age before the close of the taxable year:

Long-Term Care Benefits 2017 2016  
Age 40 or younger$410$390 
Over 40 but under 50$770$730 
Over 50 but under 60$1,530$1,460 
Over 60 but under 70$4,090$3,900 
Over 70$5,110$4,870 

The new guidance is in addition to 2017 retirement plan limits that the IRS also released in October. The 2017 limits for contributions to health savings accounts and for high-deductible health plans were released earlier, in May 2016. Separately, the Social Security Administration announced an increase in the Social Security taxable wage base and adjustments to income tax brackets for 2017.

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