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IRS Announces 403(b) Compliance Project and HSA Limits for 2012

    Client Alerts
  • May 20, 2011

The IRS recently announced a compliance project with respect to 403(b) plans maintained by higher education organizations. This project is designed to determine whether colleges and universities that sponsor 403(b) plans satisfy the universal availability rule. Under the program, the IRS will send a "compliance contact letter" to about 300 randomly selected institutions. This letter is not an audit, but responses that indicate a possible failure to satisfy the universal availability rule could lead to corrective action, and failure to respond could lead to an audit. The link below describes this compliance initiative in more detail:,,id=238459,00.html

The IRS also recently issued Revenue Procedure 2011-32 announcing the inflation adjusted amounts for health savings accounts ("HSAs") for calendar year 2012 as determined under Section 223 of the Internal Revenue Code.

The 2012 limits include the following:

Annual HSA contribution limits: $3,100 for self-only high-deductible health plan ("HDHP") coverage and $6,250 for family HDHP coverage.

HSA catch-up contribution limit (applicable to individuals who are age 55 or older): $1,000.

HSA required minimum annual HDHP deductible: $1,200 for self-only HDHP coverage and $2,400 for family HDHP coverage.

Maximum HDHP out-of-pocket expense (including items such as deductibles, co-payments and co-insurance, but not premiums): Limited to $6,050 for self-only HDHP coverage and $12,100 for family HDHP coverage.