Tag Archives: HSA Funding

Can Spouses Have Both an HSA and FSA?

This question was submitted by HSA Edge reader Eugenia. Feel free to submit your question today to evan@hsaedge.com.

My husband and I have different employers, and we would like to use an HSA and FSA. This November is an open enrollment for Health Insurance for 2018 and my husband plans to enroll in an HDHP Plan with self only coverage. Since my employer does not offer an HDHP, I will enroll myself and my son a PPO plan. Can we have both FSA medical and HSA? Since my husband’s insurance is self only coverage and my insurance is self and child only coverage. And how can my husband open the Health Savings Account?

You are correct in questioning the same year FSA and HSA contribution. Unfortunately, the IRS has deemed that FSA coverage extends tax benefits to family members as well. This is because an FSA holder can deduct medical expenses that occur for themselves, their spouse, and their dependents. This also applies inversely for HSA’s since they can deduct expenses for their family. This combination of two tax advantaged programs is a no-no as it violates the “No Other Health Coverage” clause of the HSA. (see Qualifying for an HSA).

Do note that there are some types of Flexible Spending Accounts that are compatible with HSA’s, such as Limited Purpose FSA’s and Post Deductible FSA’s. However, these are not as common as your regular FSA’s and they must be explicitly stated as such. Thus, it is up to the family to choose the HSA or FSA to avoid double coverage. You cannot have both. In making a decision, see this article regarding Choosing between an HSA and FSA.

As for opening an HSA, as long as your husband has a qualifying High Deductible Health Plan, he can open an HSA at whatever financial institution he wants. Here is a similar situation involving Opening an HSA when Your Employer does not Offer One. It is pretty easy. I suggest comparing banks that offer the lowest fees and best investment options to make a choice.

When it comes to contributing to the HSA, your husband can directly contribute to his HSA instead of taking salary deductions. This will be done with post-tax dollars, so he just writes a check to the Health Savings Account. Come tax time, when you file Form 8889, it will reduce your taxable income by the contribution amount, making those contributions tax free. However, do note that there is one disadvantage of contributing directly to the HSA, which is additional Social Security / Medicare taxes are paid. If you withhold the contributions from your paycheck, you never pay those extra taxes. If you contribute the post-tax money, you will have paid those taxes, but only get back the federal income tax you paid. It might not matter.

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Contributing to HSA’s with a Cafeteria Plan

What are Cafeteria Plans

To understand Cafeteria Plans and HSA’s, it helps to understand the mechanisms for contributing funds to your Health Savings Account. There are four different ways to contribute to an HSA, all of which count towards your yearly contribution limit:

Your employer contributes their money to your HSA. In this case, your employer gifts you funds directly into your Health Savings Account during the tax year. This is by far the best way to fund an HSA since the money is free and being given to you. Employer contributions count towards your yearly contribution limit but they are yours to spend as you like.
You contribute after tax money to your HSA. This usually occurs by depositing cash or transferring funds between your bank account and your Health Savings Account. You have likely paid taxes on these funds (via payroll) so HSA tax Form 8889 helps you account for them and refund those taxes paid.
You contribute from your IRA or Roth IRA. This is called a Qualified Funding Distribution and moves money from one tax advantaged investment account to your HSA. Do note that these contributions contain a Testing Period,
requiring you to maintain HSA insurance.
Your employer withholds your earnings pre-tax and contributes them to the HSA. This is an example of a what is called a cafeteria plan. These funds are yours (since they are being paid to you and are no longer your employer’s) and are a part of your paycheck. The employer is just enabling the contribution for you through their payroll system.

Cafeteria Plans are not unique to HSA’s; in fact, it is a general term used to describe pre-tax contributions made by your employer. They can be established for a variety of employee related savings or expenses.

A Cafeteria Plan is a reimbursement plan governed by IRS Section 125 which allows employees to contribute a certain amount of their gross income to a designated account or accounts before taxes are calculated.

Benefits of HSA Cafeteria Plans

There are numerous benefits of cafeteria plans that not only make your life easier, but actually end up saving money. Besides all of the advantages of savings in an HSA, here are some additional benefits that contributing via a Cafeteria Plan provides:

You pay less taxes. You read this right, Cafeteria Plans reduce the amount of taxes you pay. This is because payroll tax is not the only tax you pay each paycheck. In addition, you pay into other programs such as Medicare, Social Security, and any state taxes that are taken from your earnings. When you file Form 8889 as part of your tax return, you will only be credited for the income tax that was paid. The other taxes stay with Uncle Sam. Using a cafeteria plan allows you to make these contributions before all these payroll taxes hit it, allowing you to keep a larger slice of your earnings.
Disciplined savings. One of the hardest things about saving is actually putting aside the money to save. There is always something that comes up or something tempting you as a “more fun” use of the money. Saving via a Cafeteria Plan eliminates this because you automate your savings plan and the money is taken pre-tax. It never even hits your checking account as it goes straight to the HSA, preventing you from spending it and making sure you make your contribution.
Easier transactions. I never had the luxury of a cafeteria plan so each month I had to initiate a transfer to my bank to make the contribution. Having this taken care of for you reduces the amount of work you have to do and transfers you make with your money.

If you are presented the option for contributing to an HSA via cafeteria plan you should definitely consider it, based on the benefits above. Their main drawback is decreased flexibility in changing HSA contributions, since they are happening automatically from your paycheck. For example, it may take time to adjust your HSA contribution amount during the year. There may be a lockout period, a delay before it takes effect, and you at least have to talk to HR to make the change. You should evaluate how your specific payroll plan handles changes to HSA contributions via a cafeteria plan and assess whether that is suitable to your needs before signing up.

Reporting Cafeteria Plan Contributions on Form 8889

The biggest mistake people make with Cafeteria Plan contributions and filing HSA tax Form 8889 is putting them on Line 2. Line 2 is where contributions you personally made (#2 above) are totaled and used to reduce your taxable income. This has the effect of making your contributions tax free. You can see that by adding Cafeteria Plan contributions to this line, you are “double dipping” because you never paid taxes on those contributions to begin with. Line 2 has a disclaimer that calls this out:

Do not include employer contribuitons, contributions made through a cafeteria plan, or rollovers in Line 2 (see instructions)

Due to the IRS’ confusing wording, most people don’t even know they are contributing through a cafeteria plan or what one is. Thus, they end up making a mistake on Form 8889 and potentially receiving a call from the IRS.

The correct place to put contributions made through a cafeteria plan is on Line 9 of Form 8889, which is called “Employer Contributions”. This makes sense because, in our discussion above, we saw how cafeteria plan contributions look a lot like employer contributions. There is no taxes being paid on both of these contributions, it is just a matter of whose money is being contributed. Again, the IRS doesn’t help us with Form 8889 because they describe the line as “Employer contributions made to your HSA for 2017”.

If you look into the Form 8889 instructions, you can see that this is the exact spot where Cafeteria Plan contributions should go:

Doing so will ensure the amount that travels over to your 1040 form is the correct amount to deduct.

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Note: if you need help with cafeteria plan contributions on Form 8889, please consider using my service EasyForm8889.com. It asks you simple questions and fills out Form 8889 perfectly for you in about 10 minutes.

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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