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February 11, 2020


Health Savings Accounts (HSAs) and Medicare


Medicare enrollment impacts an otherwise eligible
individual's ability to establish and contribute to a health
savings account (HSA). Although Medicare enrollees
cannot establish HSAs or make or receive contributions to
their existing accounts, these individuals can withdraw any
remaining balances in previously established accounts. This
In Focus provides an overview of HSA rules and highlights
how these rules apply to Medicare enrollees.


HSAs are tax-advantaged accounts that individuals can use
to pay for unreimbursed medical expenses (e.g.,
deductibles, co-payments, coinsurance, and services not
covered by insurance). Although eligibility to contribute to
an HSA is associated with enrollment in a high-deductible
health plan (HDHP), HSAs are trust/custodial accounts and
are not health insurance.


Individuals are eligible to establish and contribute to an
HSA if they meet three requirements in a given tax year:
they have coverage under an HSA-qualified HDHP, they do
not have disqualifying coverage, and they cannot be
claimed as a dependent on another person's tax return.

To be HSA qualified, an HDHP must (1) have a deductible
above a minimum level (in 2020, $1,400 for self-only
coverage and $2,800 for family coverage); (2) limit out-of-
pocket expenditures for covered benefits to no more than a
maximum level (in 2020, $6,900 for self-only coverage and
$13,800 for family coverage); and (3) cover only preventive
care services before the deductible is met.

Disqualifying coverage is generally considered any other
health coverage that is not an HSA-qualified HDHP or that
provides coverage for any benefit also covered under an
individual's HSA-qualified HDHP. For example,
individuals with an HSA-qualified HDHP are not eligible to
establish or contribute to their HSA if they also are covered
under a spouse's policy that is not an HSA-qualified
HDHP.

HSA
If an individual is eligible to contribute to an HSA anytime
during a given tax year, the total amount that individual
may contribute (or may have contributed on his or her
behalf e.g., by an employer) to his or her HSA is capped.
Generally, the maximum amount an individual may
contribute to his or her HSA in a tax year is based on the
months during the year that he or she was considered HSA
eligible; the type of HDHP coverage the individual had
during those months (self-only or family); and the
individual's age (those aged 55 or older are allowed
additional catch-up contributions).


For 2020, the maximum annual amount an individual with
self-only coverage can contribute to his or her HSA is
$3,550 and the maximum annual amount an individual with
family coverage can contribute to his or her HSA is $7,100.
For those aged 55 or older, the maximum annual amount an
individual can contribute to his or her HSA is increased by
$1,000. Contribution limits are determined based on the
months individuals are considered eligible, and individuals
may have lower contribution limits if they were not eligible
for the entire year.

HW'SA Wtd~st
Account holders may make tax-free HSA withdrawals to
pay qualified medical expenses for themselves, their
spouse, or their dependents.

For HSA purposes, qualified medical expenses include the
costs of diagnosis, cure, mitigation, treatment, or prevention
of disease and the costs for treatments affecting any part of
the body; the amounts paid for transportation to receive
medical care; and qualified long-term care services. Except
for limited circumstances, health insurance premiums and
over-the-counter medicines are not considered qualifying
medical expenses.

Withdrawals not used to pay for qualified medical expenses
must be included in an individual's gross income when
determining federal income taxes and generally also are
subject to a 20% penalty tax.

Individuals who subsequently become ineligible to
contribute to their HSAs retain access to their accounts and
may continue to withdraw from their HSAs.

HSA Ru,,s,',, Karied
Spouses are prevented from having joint HSA accounts
(even if the spouses are covered by the same HSA-eligible
HDHP). Only one spouse can be listed as the account
holder for a given HSA, even though that spouse's HSA
may be used to reimburse the medical expenses of either
spouse. Nothing prevents each spouse from establishing his
or her own HSA, assuming each is eligible.

If both spouses are HSA-eligible and at least one spouse is
covered by a family coverage HSA-eligible HDHP, then the
maximum amount the couple can collectively contribute to
its HSA(s) is associated with the family coverage annual
limit for that year ($7,100 in 2020). The collective
maximum amount is to be split evenly between the spouses'
HSAs, unless both agree on a different division. If both
spouses are aged 55 or older and eligible to make catch-up
contributions, each spouse must make such a contribution
to his or her own account; one spouse cannot make catch-up


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