Health Savings Accounts (HSAs) have become one of the more popular spending accounts for both employees and employers. HSAs are tax-favored IRA-type trust or custodial accounts that can be contributed to by, or on behalf of, “eligible individuals” who are covered by certain High-Deductible Health Plans (HDHPs). The HSA can be used to pay for certain qualified medical expenses of the eligible individuals and their spouses and tax dependents.
Only an “eligible individual” can establish an HSA and make HSA contributions or have them made on his or her behalf. There are two groups of individuals who are ineligible for HSA contributions: those who can be claimed as tax dependents, and those who are entitled to Medicare. As a side note, “entitled to Medicare” means enrolled in and receiving Medicare benefits. Thus, mere eligibility for Medicare benefits (without enrollment) will not disqualify an individual from HSA eligibility.
An HSA-eligible individual can make contributions (up to statutory limits) to an HSA and get an “above-the-line” tax deduction, which means that the contributions reduce the individual’s adjusted gross income before itemized or standard deductions are considered. On the other hand, instead of an “above the line” deduction, many employers permit employees to contribute to an HSA on a pre-tax basis through the employer’s cafeteria plan [Note: An employee having deductions done pretax through an employer cannot also take an above the line deduction on tax forms]. Any investment earnings generated on HSA funds are also generally tax-free. HSA funds withdrawn for qualified medical expenses escape federal taxation entirely.
In order to be eligible to establish an HSA, an individual must be covered under an HDHP for the months for which contributions are made to the HSA. In addition, an eligible individual cannot have coverage under any non-HDHP that provides coverage for any benefit covered by the HDHP. IRS guidance interprets this coverage restriction to mean that any other health coverage, that is not a HDHP would disqualify an otherwise eligible individual unless it only constitutes preventive care, certain permitted coverage, or certain permitted insurance. As a reminder, this prohibition on having other non-HDHP coverage includes health plans such as health Flexible Spending Accounts (health FSAs) or Health Reimbursement Arrangements (HRAs).
It’s not too early to start reviewing current employee benefits offered and planning on what to provide in 2018. An employer currently offering a HDHP in conjunction with an HSA needs to ensure that any health plan limitations will meet the IRS requirements.
As a benefit to Chamber members, JRG Advisors, the management team behind ChamberChoice, are available on a consultative basis to assist members in planning their healthcare benefits offerings. They can be reached at 1-800-377-3539 or visit their website for more information.