Other health coverage that can block HSA contributions
Inventory overlapping medical plans, FSAs, HRAs, government benefits, and permitted insurance before funding an HSA.
Coverage that pays medical expenses before the HDHP deductible generally blocks HSA contributions unless it is permitted insurance, preventive coverage, or another specifically allowed arrangement.
Build a complete coverage inventory
List another group plan, a spouse's plan, health FSA, HRA, Medicare, Medicaid, TRICARE, Veterans benefits, and direct employer reimbursement. Identify who can claim benefits and when. Eligibility turns on available coverage, not only claims actually submitted.
Know the permitted categories
Dental, vision, disability, long-term care, specified-disease, fixed-hospitalization, accident, workers' compensation, and certain liability coverage can be permitted. A broad medical policy does not become permitted merely because it is secondary to the HDHP.
Example and common mistake
An employee keeps an HSA-qualified HDHP and buys supplemental coverage that reimburses actual medical charges. The policy needs analysis; its supplemental label is not enough. The mistake is confusing fixed-indemnity coverage with broad expense reimbursement.
Inventory coverage by what it pays
List every policy and reimbursement arrangement available to the individual, including a spouse's benefits. For each one, record who is covered, what expenses it can pay, whether payment begins before the HDHP deductible, and the effective and termination dates. Dental, vision, disability, accident, specified-disease, and qualifying fixed-indemnity coverage generally require a different analysis from broad medical reimbursement.
Do not rely on enrollment labels such as supplemental or voluntary. Review the actual benefit trigger. Coverage that pays a fixed amount upon an event differs from coverage that reimburses the medical bill itself. Preserve certificates and plan terms so the monthly HSA eligibility conclusion can be reconstructed later.
Questions to resolve
- Does another policy reimburse actual medical charges or pay a fixed benefit?
- Who can receive reimbursement under a spouse's plan?
- On what exact date did each arrangement begin or end?
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