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Exceptions to the HDHP requirement for HSAs
Exceptions to the HDHP requirement for HSAs

Can you be covered under a non-HDHP plan and still contribute to a health savings account? Likely not, but there are exceptions.

Updated over a week ago

As a reminder, here are the IRS requirements for eligible individuals.

Eligible Individual Reminder

To be an eligible individual and qualify for an HSA contribution, you must meet the following requirements.

  • You are covered under a high deductible health plan (HDHP), described later, on the first day of the month.

  • You have no other health coverage except what is permitted under Other health coverage.

  • You aren't enrolled in Medicare.

  • You can't be claimed as a dependent on someone else's 2023 tax return

Exceptions

If you are covered under anyone else's non-HSA eligible High Deductible Health Plan, you cannot open up an HSA.

The IRS permits certain coverages that will not disqualify you from opening a HSA account. This includes the following:

  1. Insurance coverage for something non-medical (e.g., workers' comp, home insurance, auto insurance, etc.)

  2. Insurance coverage for specific disease or illness (e.g., cancer policy)

  3. Hospitalization insurance where insurance pays a fixed amount per time period (e.g., days or weeks)

  4. Coverage under an Employee Assistance Program

  5. Discount cards to health services

  6. Insurance coverage for dental, vision, long-term care, accident, or disability

Source: IRC Sec. 223(c)(1)(A)(ii)

VA medical benefits

Effective January 1, 2016, The Surface Transportation and Veterans Health Care Choice Improvement Act (H.R. 3236) permits veterans enrolled in an HDHP (without any other disqualifying coverage) and who have a service-connected disability to make or receive HSA contributions regardless of when they received VA benefits.

Source: IRS Notice 2004-50 Q&A Q-5

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