Q&A: What Are the Required Deductibles for an HSA-Eligible HDHP in 2026?

Question:

Can you clarify the required deductibles for an HSA-eligible High-Deductible Health Plan (HDHP)? Our broker is telling us that for 2026, our HDHP needs to have an individual deductible of at least $3,400 and a family deductible of $6,800. However, I have read numerous reliable sources stating that the minimum deductibles are $1,700 for employee-only coverage and $3,400 for family coverage.

Which is correct?

Answer:

Great question! Both answers are technically correct, depending on how the plan is structured.

There are two types of deductibles on HDHPs: embedded and unembedded. Plans with an unembedded deductible are also known as “aggregate plans.”

First, let’s talk about plans with unembedded deductibles. The IRS minimum deductibles for these plans are $1,700 for employee-only coverage and $3,400 for family coverage. But there’s a catch: With family coverage, the plan won’t pay claims for anyone on the plan until the full family deductible is met. That means one person could end up paying the full $3,400 family deductible before the plan kicks in. The $1,700 deductible only applies to individuals with employee-only coverage.

By comparison, plans with an embedded deductible start paying each family member’s claims as soon as they meet their individual deductible. To achieve this result, the IRS requires the individual deductible to be at least $3,400 and for the family deductible to be at least $6,800.

So why would anyone choose an embedded plan when the deductibles are much higher than with an unembedded plan? The reasons differ depending on whether the plan is fully insured or self-insured.

For fully insured plans:

1. Insurance carriers have a preference for embedded deductibles and rarely quote for unembedded.
2. Unembedded options are both rare and more expensive.
3. If an unembedded deductible is available, the plans offered by carriers usually have much higher deductibles than the statutory minimums.
   

For self-insured plans:

1. The lower deductibles of an unembedded plan can result in higher claims paid and, ultimately, higher premiums.
2. Additional factors that may influence your decision include employee confusion and satisfaction, ease of administration, compliance concerns, and cost controls.
   

Most of our clients choose embedded deductibles for the above reasons and others. Your benefits advisor can help you weigh the pros and cons of the two approaches and decide on which suits you best.

Not a client of The Miller Group? Connect with one of our employee benefits advisors to learn how our compliance team can help you stay on track and confidently meet your obligations.