HSA eligibility checklist: test every requirement
Work through HDHP coverage, other coverage, Medicare, dependency, and the first-day-of-month rule before contributing.
You may contribute for a month only if you have HSA-qualified HDHP coverage on the first day, no disqualifying other coverage, no Medicare enrollment, and no status as someone else's claimable tax dependent.
Run the four-part test monthly
Confirm the plan is HSA-qualified rather than merely high deductible. Inventory every other medical arrangement, including a spouse's FSA or HRA. Check Medicare's effective date and determine whether another taxpayer can claim you as a dependent for the contribution year.
Use documents, not account labels
Read the Summary of Benefits and Coverage, plan document, FSA or HRA terms, Medicare notice, and dependency facts. An HSA custodian can accept money without deciding whether the deposit is permitted. Re-run the test whenever employment, marriage, or coverage changes.
Example and common mistake
A worker enrolls in an HSA-labeled employer plan while a spouse's general-purpose FSA can reimburse the worker's expenses. The FSA may block contributions even if no claim is filed. The mistake is treating the plan's HSA label as the entire eligibility test.
Evidence for each eligibility element
Create one file for the tax year with the HDHP Summary of Benefits and Coverage, enrollment effective date, spouse benefit elections, FSA and HRA plan terms, Medicare records, and dependency facts. The useful question is not whether an account was used; it is whether another arrangement could reimburse nonpreventive expenses before the HDHP deductible.
Repeat the review after marriage, divorce, a job change, a spouse's open enrollment, VA treatment, Medicare enrollment, or a change in dependent status. Mark the first day each change became effective. That date determines the first affected contribution month and is more reliable than a payroll system's HSA eligibility flag.
Questions to resolve
- Can any non-HDHP arrangement reimburse the individual before the deductible?
- Did Medicare, dependency, or spouse benefit elections change during the year?
- Which effective-date documents support every eligible month on the schedule?
Federal authority record
- U.S. House Office of the Law Revision Counsel: 26 U.S.C. section 223 - Health savings accounts
HSA eligibility, contribution limits, qualified distributions, and beneficiary rules - IRS: Publication 969 — HSAs and other tax-favored health plans
Monthly eligibility, last-month rule, spouses, Medicare, and excess contributions - IRS: Notice 2008-59 - Health Savings Account questions and answers
Other coverage, monthly eligibility, contribution, and distribution questions