Category Archives: HSA mechanics

HSA Contribution with FSA Carryover / Grace Period

Overview

We have established that you cannot contribute to an HSA if you or your spouse has a Flexible Spending Account (FSA). This is because FSA coverage is considered “other health coverage” which prevents one from being HSA eligible. Since FSA benefits extend to the holder as well as their spouse and dependents, this can disqualify some otherwise ready people from contributing to HSA’s. Per IRS form 969:

An employee covered by an HDHP and a health FSA or an HRA that pays or reimburses qualified medical expenses generally can’t make contributions to an HSA

The exceptions to the above quote include limited purpose health FSA or HRA, Suspended HRA, post-deductible FSA or HRA, and retirement HRA.

Carryover and Grace Period defined

Generally, FSA’s are “use it or lose it” type plans where any unused funds disappear at the end of the year. This contrasts sharply with HSA’s where the funds are yours forever. To cushion this blow, the IRS allows for two FSA options available to the plan administrator. Generally only one of the following can be chosen per FSA:

Grace Period – for 2.5 months following the end of the plan year, you can use prior year funds to pay for qualified medical expenses. This effectively extends the “lose it” deadline. That means up until March 15th you can still use your prior year FSA funds.
Carryover – your plan may allow up to $500 to be brought forward into the current year to spend on qualified medical expenses. You then have access to this money for the entire year. Any amount above this is forfeit. In other words, you can maintain $500 in your FSA indefinitely.

Can I contribute to my HSA if I carryover FSA funds?

These provisions effectively extend the life of your current year FSA funds. However, a fairly common scenario is ending FSA coverage with a carryover / grace period and beginning HSA eligible coverage. What happens when the FSA carryover interferes with HSA coverage? Are these people HSA eligible, and can they contribute?

HSA with FSA Grace Period

Surprisingly, the IRS provides explicit guidance to the carryover or grace period provision that many FSA’s contain. In IRS form 969 they state:

Coverage during a grace period by a general purpose health FSA is allowed if the balance in the health FSA at the end of its prior year plan is zero.

This is great because it allows an exception to the “no other coverage” clause of HSA eligibility. As long as you zero out your FSA by December 31st, you nullify the carryover or grace period impact and can contribute to your HSA per normal. This provides relief for those whose FSA coverage is ending and HSA coverage is beginning. Of course, if your FSA policy ends and you no longer have access to it, there is no effect on your HSA contribution.

HSA with FSA carryover

The IRS does not call out the FSA carryover provision and how it affects HSA contributions. I believe this is implicit since a carryover constitutes a continued access to FSA funds. If you have FSA funds available, you are not HSA eligible. However, if your FSA coverage ends and wipes out any carryover funds, you would then be HSA eligible, assuming all other conditions are met.

FSA / HSA contribution examples

Here are some common scenarios you might encounter with an FSA carryover or grace period and the effect on HSA contributions. Each scenario assumes you have an FSA in the current year and are switching to an HSA eligible plan in the new year:

FSA has carryover but no balance on Dec 31st – since you depleted your FSA by year end, you can contribute to your HSA for each month in the following year.
FSA has grace period of 2.5 months with balance on Dec 31st – since your FSA has a balance on January 1st, you are not HSA eligible until April 1st. This assumes the FSA coverage goes away and additional FSA funds are not made available.
You carryover $500 in your FSA into subsequent year – you cannot contribute to your HSA while covered by an FSA. As long as your FSA coverage continues and funds remain in your account, you cannot contribute to the HSA. Since the carryover period technically lasts all year, in theory this could make you HSA ineligible for the year.

The bottom line: use up any of your FSA funds by December 31st if you wish to be HSA eligible on January 1st.

Note: to fulfill the IRS requirement of tracking HSA receipts, please consider my service TrackHSA.com for your Health Savings Account record keeping. You can store purchases, upload receipts, and record reimbursements securely online.

HSA Contribution If Changing Coverage Next Year

This question was submitted by an HSA Edge reader. Feel free to send in your question today to evan@hsaedge.com.

My current insurance plan is HSA compatible, which I’ve had since January 1st, 2017. On January 1st of 2018 I am changing to a plan that is not HSA compatible. If I contribute this year and not in 2018, will I be penalized on the money contributed in 2017?

People are often concerned about over contributing to their HSA, likely on account of how easy it is to use (and abuse) the Last Month Rule. Its use allows you contribute more to your HSA in the current year, but binds you to the Testing Period, which requires you to maintain additional coverage into the following year. If you fail to do that, taxes and penalties await you.

The point to remember is you can never be penalized for contributing for months where you actually had coverage (see: Not Using the Last Month Rule when Coverage Changes). So in your case, you had coverage for 12 months in 2017 and are allowed to contribute for 12 months in 2017, which is 100% of the HSA contribution limit. In fact, the Last Month Rule doesn’t apply to you since you had coverage all year – you can’t possibly contribute more. But consider the scenario where you had coverage for only 7 months, say from June – December. You would have “earned” those 7 months and could contribute 7/12 of the contribution limit for the year without risk. However, you would also have the option to use the Last Month Rule and contribute the full year contribution limit, effectively contributing for those 5 months you weren’t covered.

This then puts you at risk since you are using the Last Month Rule to contribute more than you otherwise could have. This is allowed, and often a good idea, but if you fail to continue HSA coverage for the following 12 months (through next December), you will fail the Testing Period. This is where extra taxes and penalties come to bite you. In the prior example, those 5 months you didn’t have coverage would be added back to income (so they are taxed), plus a 10% penalty would be applied.

So using the Last Month Rule has a risk, but know that you can always play it safe and only contribute for the actual months you had coverage. If you know you are losing HSA coverage due to insurance/job/Medicare changes, do not use the Last Month Rule.

Note: if you need help with Last Month Rule calculations, or just need to file your Form 8889, please consider using my service EasyForm8889.com. It asks simple questions in a straightforward way and will generate your completed HSA tax forms in 10 minutes. It is fast and painless, no matter how complicated your HSA situation.

Health Savings Account Deadlines

Overview

Health Savings Accounts function by tax year. So 2017 is distinct from 2018, so on and so forth. Each tax year that you have HSA coverage gives you the opportunity to contribute to your HSA up to your contribution limit. However, eventually that tax year passes and you can no longer contribute to your HSA for that year. This article discusses when those timelines are and how to get the most out of your HSA for a year before the deadline.

HSA Current Year Contribution Deadline

For a given tax year, you can contribute normally to your account from January 1st until December 31st. You can contribute whatever amount you want at any time. This means that some people put the full year’s contribution in on January 1st, some contribute a pro-rata 1/12th each month, and others wait until the end of the year to make the contribution. The only risk you run by contributing early (say, in January) is over contributing. If you contribute the full amount in January, and subsequently end HSA eligible insurance, you will have excess contributions in your account that you need to remove.

The point is you can contribute to your HSA any time during the tax year. But what if you wait too long and miss that deadline?

HSA Prior Year Contribution Deadline

Luckily, the IRS is quite lenient and let’s you make prior year contributions to your Health Savings Account. This means that for a few months in the following tax year, you can make a contribution but flag it as a contribution for the prior year. The deadline for this prior year contribution is the day your taxes are due, generally April 16th.

You have up until tax day (generally April 16th) to make contributions to your Health Savings Account for the prior year. You can make contributions to your HSA for 2016 until April 18, 2017.

Note that making a prior year contribution requires a simple but special action taken with your HSA custodian. When you make the contribution, you will have to indicate specifically that it is going towards the prior tax year. This is because a contribution made in say, January, can be used for either the current year or prior year. Your HSA custodian needs to know how you handle this contribution and to which tax year you want it to count. When you make the contribution there should be an indicator for the tax year, so make sure you pick the correct one.

The IRS outlines the legalities of this in HSA Form 969:

You can make contributions to your HSA for 2016 until April 18, 2017. If you fail to be an eligible individual during 2016, you can still make contributions, up until April 18, 2017, for the months you were an eligible individual.

The interesting thing this points out is you do not need to remain an eligible individual to make prior year contributions. This means that your HSA insurance can end, but you can still wait until the following year to make prior year contributions. As an example, say you have HSA eligible insurance from January – June of 2016. Even if you contribute nothing in 2016, and even though your HSA eligible insurance has ended, you have until April 18th (tax day) of 2017 to make your full contribution limit for 2016. In this case, that would be 6/12 or 1/2 of the full contribution limit for 2016, since you had coverage for 6 months.

Deadline for HSA Employer Contributions

In addition, the deadline for employers to make contributions to your HSA for a given year is also tax day of the following year. Per IRS Form 969:

Your employer can make contributions to your HSA between January 1, 2017, and April 18, 2017, that are allocated to 2016. Your employer must notify you and the trustee of your HSA that the contribution is for 2016. The contribution will be reported on your 2017 Form W-2.

Note that the prior year employer contribution will be reported on your current year W2. This means that it will show as non-taxable income, and won’t affect that year’s contribution limit, but note that it will be there.

HSA Deadline for Reimbursement

One of the benefits of an HSA is there is no true deadline for reimbursing a qualified medical expense. To explain further, note that you can purchase health care using 1) your HSA or 2) something other than your HSA, such as a credit card or cash. If you buy a qualified medical expense with something other than your HSA, you are allowed to “reimburse” yourself for that expense at some point in the future. This reimbursement involves transferring funds from your HSA to yourself, generally the checking account. This in effect pays for the purchase with the HSA, giving you tax free medical spending.

Why would you want to do this? The benefit is that you can keep funds in your HSA longer. If you are investing your HSA, those earnings on HSA funds are growing tax free. By leaving purchases “in” your HSA and fully invested, not only is that money growing, but it is growing tax free, which is a huge IRS advantage. In addition, this reimbursable amount functions as a rainy day fund for you. You are allowed to reimburse it at any time, so if you ever need cash it can be quite helpful.

This is why record keeping and recording your HSA purchases is so important. You need to know what you have purchased, how it was paid, and whether it has been reimbursed or not. These needs were a big reason why I created and use TrackHSA.com, as it provides an audit trail for all of your HSA activity with which you can justify transactions to the IRS should they come knocking.

Note: if you need help accounting for your HSA contributions come tax time, please consider using my service EasyForm8889.com to complete Form 8889. It asks simple questions in a straightforward way and will generate your HSA tax forms in 10 minutes. It is fast and painless, no matter how complicated your HSA situation.