Employee Benefits Institute of America

Topics Covered

Here’s some of what was covered:

• Eligibility Issues. What kinds of free or low-cost medical services will not prevent HSA eligibility? What expenses can post-deductible health FSAs or HRAs pay? Can an HRA pay HDHP premiums without preventing HSA eligibility (and what HRA or HIPAA compliance issues would such an arrangement raise)?
• Contribution Issues. How do employers report contributions that relate to a prior year? When can employers recoup mistaken contributions? Can employers make contributions to the HSAs of non-employees (e.g., spouses, domestic partners)?
• Distribution Issues. Can debit cards be used with HSAs? Can third parties be authorized to access HSA funds?
• Prohibited Transactions. Is there any borrowing, loaning or pledging allowed for HSAs? What are the consequences of a prohibited transaction?
• When is an HSA established? What rules apply to rollover HSAs or successive HSAs?
• How does the full-contribution rule work? What are the implications for employers? How do excess contribution and testing period violation penalties coordinate?
• Qualified HSA funding distributions. Who is eligible? What is the tax treatment? How do the testing period rules interact with those of the full-contribution rule?