Category Archives: How To

How to Rollover HSA Funds

At some point you may find yourself with multiple Health Savings Accounts that you wish to combine or transfer money between. While the actual transaction is easy to accomplish, there are potential tax implications per the IRS, as this transaction ends up on Form 8889, so it is best to play by the rules and do it correctly. This article will outline those rules to rollover your HSA.

HSA Rollover Definition

The IRS defines an HSA rollover as:

A rollover is a tax free distribution (withdrawal) of assets from one HSA or Archer MSA that is reinvested in another HSA of the same account beneficiary.

Note they define a rollover as a distribution that occurs in an effort to move money between Health Savings Accounts that belong to the same owner. However, the key word is distribution which we will get to shortly. They go on to say:

Generally, you must complete the rollover within 60 days after you received the distribution.

This language confirms that you are actually receiving the money, probably in the form of a check, from the originating HSA trustee. You then have 60 days per the IRS to deposit that money in a corresponding HSA to avoid penalty. One last rule from the tax man:

An HSA can only receive one rollover contribution during a 1 year period.

The IRS puts a limit on the number of HSA rollovers that can occur during a year, which is not necessarily a calendar year. But they note that this restriction is on the receiving HSA account, not the originating account.

Direct Transfer from HSA to HSA

It is important to note that rollovers that occur directly between HSA trustees are not considered rollovers. For example, if you instruct HSA Account 1 to transfer $500 to HSA Account 2, and they transfer directly without you ever seeing it, this is not a rollover. Instead, the IRS deems this a transfer:

If you instruct the trustee of your HSA to transfer funds directly to the trustee of another of your HSAs, the transfer is not considered a rollover. There is no limit on the number of these transfers. Do not include the amount transferred in income, deduct it as a contribution, or include it as a distribution on Form 8889.

Thus, the same rules do not apply to transfers and HSA rollovers. Transfers are much more flexible and frequent. Likely, the IRS imposes tight rules on Rollovers since they “lose sight” of the money for a while, which opens the door for non qualified HSA spending. The key test is in the distribution, determined by whether you physically receive the HSA funds (check) to redeposit in another HSA.

HSA Rollover vs Transfer Comparison

This table clarifies the difference between HSA rollovers and transfers:

	Rollover	Transfer
Funds transferred	to you, then to receiving HSA	directly to receiving HSA
Time to complete	60 days	None (instant)
Form 8889 impact	Include in 14a and 14b	Not included
Frequency Limits	Once every 12 months	No limit
Affects HSA Contribution Limit	No	No
Included in income	No	No
Deductible	No	No
Difficulty	medium	easy

HSA rollover rules

To summarize the rules for rolling over your HSA:

Initiate the distribution from your originating HSA trustee, and they will send you a check
Upon receiving the HSA funds, redeposit them with the receiving HSA trustee within 60 days
You may only make one rollover during each 1 year period, beginning on the date you make the deposit.
Record this as an HSA rollover on Form 8889, lines 14a and 14b.

Should I transfer or rollover my HSA?

In general, I would opt for a direct transfer of your HSA. This is done by instructing your HSA trustee to move money to another HSA trustee. The reason is it is much simpler for you to execute and takes less time. You don’t have to wait for the check, spend time depositing it in your other HSA, and then remember and figure out how to report it at tax time on HSA Form 8889. Plus, you can do as many of these transactions as you wish during the year.

How to report HSA rollover to the IRS

One disadvantage of a true HSA rollover is that you will need to report it on IRS tax Form 8889. When properly accounted, a rollover will not adversely affect you in terms of taxes, penalty, or contribution limit; it is a totally legitimate transaction. Instead, it is more of a nuisance as you have to remember to report it to satisfy the IRS and correctly file Form 8889.

On Form 8889, you will need to include the amount of your HSA rollver distribution on both:

Line 14a – Total distributions you received from all HSA’s
Line 14b – Distribution included on line 14a that you rolled over to another HSA.

Here is an example of what Form 8889 looks like for 2015 with only a $1000 HSA Rollover:

form8889_hsa_rollover_line_14

The above was prepared by EasyForm8889.com, which asks simple questions like this to complete HSA Form 8889:

Transfer your HSA to a New Employer

Depending on how your employer’s HSA is setup, there may not be any work to transfer your HSA to a new employer. In one situation, you go to a new employer who offers HSA eligible insurance, but does not contribute or offer cafeteria plan (removed from your paycheck) contributions. In that case, you manage the HSA yourself, and can maintain the account at whatever financial institution you wish.

However, if your employer is making contributions or your contributions will be made through a cafeteria plan, you may need to transfer funds to your new HSA. You have the option of receiving and redepositing (Rollover) the HSA funds, or just initiating a trustee to trustee transfer for the HSA funds. Either one will work, but note the advantages above of the simpler transfer method. Generally, this will be a good idea to minimize your account fees and manage your HSA in one spot.

HSA rollover IRA to HSA

If you wish to rollover IRA (or even 401(k)) funds to your HSA, this is not considered a rollover, but instead a Qualified HSA Funding Distribution. Please see the aforementioned article for more information, as there are more restrictions and rules regarding this type of transfer.

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Note: if you have an HSA, please consider using my service EasyForm8889.com to complete Form 8889. It is fast and painless, no matter how complicated your HSA situation.

Health Savings Account Rules You Should Know

This post provides a summary of the main rules for HSA’s, for both their creation and use. Following these rules, you can understand 90% of what HSA’s are all about and avoid major pain points. Of course, due to the complicated nature of the IRS there exist corner cases you may encounter based on your situation, for which hopefully this site is a good resource.

Rule #1: You must have qualifying health insurance

You can only open a health savings account if you have a High Deductible Health Plan (HDHP). This is an IRS tax guideline, the definition of which changes each year based on inflation and other adjustments. Basically what this means is that HSA’s are an advantage only allowed to a certain subset of health insurance accounts that fall under the HDHP umbrella.

For 2017, the requirements that define HDHP insurance are below. Thus to open an HSA, your health insurance must conform to the following:

Self Only Coverage	2016	2017
Maximum annual deductible for HDHP	$1,300	$1,300
Maximum annual out of pocket limit for HDHP	$6,550	$6,550
Maximum annual HSA contribution	$3,350	$3,400
Family Coverage
Maximum annual deductible for HDHP	$2,600	$2,600
Maximum annual out of pocket limit for HDHP	$13,100	$13,100
Maximum annual HSA contribution	$6,750	$6,750

Note: besides having HSA eligible insurance, there are 3 other requirements for opening an HSA that you should be aware of but we not be covered here: 1) you cannot be enrolled in Medicare, 2) cannot be claimed as a dependent on someone else’s tax return, 3) do not have any other health insurance.

Rule #2: You must open a Health Savings Account

You must actually apply for an open an HSA account from the banking institution of your choice. Perhaps your employer helps you do this, or perhaps you open the HSA yourself. Either way, the Health Savings Account must be open before you can any expenses incurred qualify for payment from (future) HSA funds. Per IRS form 969 (2015 PDF):

You can (only) receive tax-free distributions from your HSA to pay or be reimbursed for qualified medical expenses you incur after you establish the HSA.

So the actual HSA contributions do not need to be in your account, but any medical costs you incur before opening the account are not qualified and cannot be paid with (tax free) HSA dollars.

Rule #3: Know your HSA contribution limit for the year

There is a maximum amount you can contribute to your HSA each year called your contribution limit. This amount varies based on a number of factors that may apply to your situation. The simple case is if you had health insurance all year, the contribution limit for 2017 for self only insurance is $3,400 and for family insurance is $6,750. If you are 55 or older, you can add an additional $1,000 to that. If you are married and both have HSA’s, you have to share the $6,750.

If you had partial year coverage, more complicated rules apply. Generally a pro rata (by month) allocation of the contribution limit for your insurance occurs. If you began HSA coverage this year, you may take advantage of the Last Month Rule. This optionally allows you to contribute up to the contribution limit for the year, even if you had partial year coverage. However, do so with caution: if you fail to maintain the Testing Period, these contributions will be considered excessive and taxes and penalties attached.

Rule #4: Spend your HSA only on Qualified Medical Expenses

In order to receive tax benefits of HSA’s, you must play by the IRS’s rules regarding how they are spent. They detail these as Qualified Medical Expenses which include a wide variety of medical items such as prescription drugs, copay’s, doctor’s visits, dental work, eye care, child care, surgeries, tests, hospital fees, acupuncture, etc. For HSA contributions to be spent tax free, they must be spent on qualified medical expenses. If HSA funds are spent on anything other than qualified medical expenses, they will be taxed and penalized.

This tax/penalty calculation occurs when you file HSA tax Form 8889 for your yearly taxes, as you will be asked two questions regarding your HSA.

How much was spent from your HSA during the year?
How much was spent was spent on qualified medical expenses during the year?

Any difference noticed above (amount not spent on QME) will be taxed and penalized.

Rule #5: Record all of your HSA transactions

So how does the IRS know that you spent your HSA funds on qualified medical expenses? For one, they require that you maintain proof regarding all of your purchases made with your HSA. While they do not ask for it each year, they reserve the right to audit your HSA tax filings at any time. In this scenario, the burden is on you to substantiate all of your HSA spending for a given year(s). You are required to provide proof that the amounts you deducted for your HSA were spent entirely on qualified medical expenses, and likely show receipts that this spending occurred. Not being able to prove this could result in your HSA spending being reclassified as “non qualified” and taxes and penalties assessed.

There are a number of ways you can store this information, from the simple file or shoebox to the high tech excel file or custom website such as TrackHSA.com. Whatever method you choose, be sure that you maintain this information to protect yourself from the tax man.

Rule #6: Account for your HSA taxes correctly

The best laid HSA plans are all for not if you file your taxes incorrectly. Imagine if you save in your HSA for years, use the funds correctly, and diligently record all of your medical expenses and maintain records. If this activity fails to make it to your 1040 tax form in the proper manner, it does not matter and the whole effort has been wasted. In this scenario, you will find yourself paying excessive taxes which could have been avoided.

Form 8889 is the crucial link to insure that the HSA’s tax advantages make there way to Form 1040 in the correct manner. I recommend the use of EasyForm8889.com to accurately complete your HSA tax form 8889, no matter what your HSA situation for the year. With Form 8889 being the main HSA input, the main output on Form 1040 will be your tax liability, which hopefully your HSA has helped reduce.

TrackHSA.com – manage your HSA purchases, receipts, and reimbursements online for free

After being unhappy with my combination shoebox / Excel file HSA tracking system, I designed and created TrackHSA.com to better manage my Health Savings Account. TrackHSA is the first website that allows anyone to track their HSA account activity securely online for free.

HSA’s have a lot of moving parts including funding, taxation, purchases, reimbursements, and government required record keeping. Most HSA custodians (banks) track the in’s and out’s of your actual bank account, but there is little qualitative information about what those transactions were for and how they were justified. The government requires this sort of information for tax filing and it was a pain to maintain. TrackHSA solves this by creating a log of all your HSA eligible purchases, their details, whether or not they have been reimbursed, and allows you to attach a receipt to justify the expense.

It started based on my personal aggravations with my HSA:

keeping receipts in a shoe box
manually maintaining purchase history in Excel on one computer
not knowing how much I could withdraw from my HSA account to reimburse credit card purchases
incomplete information when tax time rolled around

TrackHSA addresses this by:

uploading a receipt to each purchase, storing it safely in the cloud
maintaining a purchase history securely online, accessible from anywhere
calculating your reimbursable amount based on all prior transactions
suggests additional detail for each purchase to help with IRS Form 8889

Hopefully you find it useful, the site is free and the data is stored securely and anonymously on Google’s servers.

Please contact me at Evan@HSAedge.com if you have any questions. If you know someone who would benefit from this free service, please share it with them.

HSA Edge

A resource to help you maximize your Health Savings Account