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The Basics of HSAs

          Roy Ramthun
Senior Advisor for Health Initiatives
    U.S. Treasury Department
HSA Overview
HSA is money put in an account owned by
an individual to pay for future medical
expenses
Must be used in conjunction with “High
Deductible Health Plan” (HDHP)
– Insurance that does not cover first dollar
  medical expenses (except for prevention)



                                    2
Who Is Eligible for HSAs?
Any individual that:
– Is covered by a HDHP
– Is not covered by other health insurance
     does not apply to specific injury insurance and accident,
     disability, dental care, vision care, long-term care
– Is not eligible for Medicare
– Can’t be claimed as a dependent on someone else’s
  tax return
Contrast with Archer MSA rules
– Had to be employed by small employer (50 or fewer)

                                                 3
What Is a “High Deductible
     Health Plan” (HDHP)?
Health insurance plan with minimum deductible of:
– $1,000 (self-only coverage)
– $2,000 (family coverage)
Annual out-of-pocket (including deductibles and co-pays)
does not exceed:
–   $5,000 (self-only coverage)
–   $10,000 (family coverage)
–   These are lower than Archer MSAs
HDHPs can have:
– no deductible for preventive care
– higher out-of-pocket (copays & coinsurance) for non-network
  services


                                                4
HSA Contribution Rules
Contribution to HSA can be made by
either the employer or the individual, or
both
– If made by the individual, it is an “above-the-
  line” deduction
– If made by the employer, it is not taxable to
  the employee (excluded from income)
– Can be made by others on behalf of individual
  and deducted by the individual
All contributions are aggregated5
HSA Contribution Rules
Maximum amount that can be contributed
to an HSA (and deducted) = lesser of:
– Amount of High Deductible
   or
– Maximum specified in law (indexed annually
  by M-CPI)
    $2,600 (self-only coverage) - 2004
    $5,150 (family coverage) - 2004
Reduced by any contribution to an Archer
MSA
                               6
HSA Contribution Rules

                                             Maximum
                        Out-of-Pocket
                                            HSA Deposit
           Deductible    Maximum
                                              (2004)
            $1,000         $5,000             $1,000
            $1,500         $5,000             $1,500
 Single
            $2,000         $5,000             $2,000
Coverage
            $2,500         $5,000             $2,500
            $3,000         $5,000             $2,600
            $2,000        $10,000             $2,000
            $3,000        $10,000             $3,000
 Family
            $4,000        $10,000             $4,000
Coverage
            $5,000        $10,000             $5,000
            $6,000        $10,000             $5,150

                                        7
HSA Contribution Rules
Contributions to Archer MSAs were limited
to:
– 75% of the deductible amount for family (65%
  for self-only plans)
– Employee’s compensation or self-employment
  income
If employer made a contribution, employee
could not

                                  8
HSA Contribution Rules
For individuals age 55 and older, additional
“catch-up” contributions to HSA allowed
–   2004 - $500
–   2005 - $600
–   2006 - $700
–   2007 - $800
–   2008 - $900
–   2009 and after - $1,000
Contributions must stop once an individual is
eligible for Medicare
                                     9
HSA Contribution Rules
Contributions can be made through cafeteria
plans
Rollovers from Archer MSAs and other HSAs
permitted
Employer contributions to HSA must be
“comparable” for all employees participating in
the HSA
– If not comparable, there will be an excise tax equal to
  35% of the amount the employer contributed to
  employees’ HSAs



                                          10
HSA Contribution Rules
In order to meet the requirement that the employer make
comparable contributions, the employer must make
contributions:
– which are the same amount
    or
– which are the same percentage of the annual deductible
Count only employees who are eligible individuals
covered by the employer and who have the “same
category of coverage” (i.e., self-only or family)
Part-time employees are tested separately
“Part-time” means customarily employed fewer than 30
hours per week

                                               11
HSA Distributions
Distribution is tax-free if taken for “qualified
medical expenses”
– Now includes over-the-counter drugs
Cannot be used to pay for other health insurance
except:
– COBRA coverage
– Qualified long-term care insurance
– Health plan coverage while receiving unemployment
  compensation
– For individuals eligible for Medicare:
     Medicare (Part A, Part B, Medicare+Choice)
     Employee share of premiums for employer-based coverage
     Cannot pay Medigap premiums               12
HSA Distributions
Distributions are tax-free if taken for:
– person covered by the high deductible
– spouse of the individual
– any dependent of the individual
Spouse and dependents don’t need to be covered by the
HDHP
If not used for qualified medical expenses, then amount
is included in income
10% additional tax if taken for non-medical expenses,
except when taken after:
– Individual dies or becomes disabled
– Individual is eligible for Medicare
Compare to 15% additional tax for Archer MSAs

                                           13
HSA Distributions
HSA custodian must report all distributions
– not required to check them for eligibility
Under Archer MSA rules, the MSA
custodian does not have to determine
whether MSA distributions are used for
medical purposes; the individual does that
Given the less stringent distribution rules
for HSAs, we assume Archer MSA holders
will rollover to HSAs

                                14
HSA Distributions
Should the HSA participant keep receipts?
– YES! Need to prove that deductible was met
– Not all medical expenses paid out of the HSA
  have to be charged against the deductible
  (e.g. prescription sunglasses)




                                  15
Estate Treatment of HSAs
If married, the spouse is treated as the owner
In other cases:
– The account will no longer be treated as an HSA upon
  the death of the individual
– The account will become taxable to the recipient of it
  (including the estate of the individual)
     Taxable amount will be reduced by any qualified medical
     expenses incurred by the deceased individual before death
     and paid by the recipient of the HSA
     The taxable amount will also be reduced by the amount of
     estate tax paid due to inclusion of the HSA into the deceased
     individual’s estate


                                                16
Advantages of HSAs
HSA accounts encourage savings for future
medical expenses

– When employer-sponsored coverage is lost
  during periods of unemployment
     COBRA continuation coverage
     other coverage
– Insurance coverage or medical expenses after
  retirement (before Medicare eligibility)
– Long-term care expenses
– Out-of-pocket expenses for Medicare
– Non-covered services under future coverage
                                     17
Advantages of HSAs
Accounts are owned by the individual (not an employer)
Individual decides:
     How much to contribute
     How much to use for medical expenses
     Which medical expenses to pay from the
     account
     Whether to pay for medical expenses from the
     account or save the account for future use
     Which company will hold the account
     What type of investments to grow account


                                         18
Advantages of HSAs
Accounts are completely portable, regardless
of:

–   Whether the individual is employed or not
–   Which employer the individual works for
–   Which state an individuals moves to
–   Age or marital status changes
–   Future medical coverage




                                        19
Advantages of HSAs
No “use it or lose it rules” like Flexible Spending
Arrangements (FSAs)

– Unspent balances in accounts remain in the
  account and can grow through investment
  earnings
– Encourages account holders to spend their funds
  more wisely on their medical care
– Encourages account holders to shop around for
  the best value for the health care dollars



                                      20
Advantages of HSAs
Accounts can grow through investment
earnings

– Many different investment options could be
  pursued
– Individual chooses investment option that best
  meets their needs

HDHP premiums should be cheaper than
health insurance with traditional deductibles


                                      21
HSA Issues
Prevention
Rx drugs
Coordination with HRAs & FSAs
Individual vs. Family deductibles
Substantiation




                                22
Treasury Activities
Initial guidance issued 12/22/03
Guidance continued monthly on
– Prevention
– Treatment of Rx drugs
– Coordination with HRAs & FSAs
– Model HSA plan document
Additional guidance coming in July, 2004
Formal regulations in 2005
                                   23

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Hsa basics presentation_treasury dept

  • 1. The Basics of HSAs Roy Ramthun Senior Advisor for Health Initiatives U.S. Treasury Department
  • 2. HSA Overview HSA is money put in an account owned by an individual to pay for future medical expenses Must be used in conjunction with “High Deductible Health Plan” (HDHP) – Insurance that does not cover first dollar medical expenses (except for prevention) 2
  • 3. Who Is Eligible for HSAs? Any individual that: – Is covered by a HDHP – Is not covered by other health insurance does not apply to specific injury insurance and accident, disability, dental care, vision care, long-term care – Is not eligible for Medicare – Can’t be claimed as a dependent on someone else’s tax return Contrast with Archer MSA rules – Had to be employed by small employer (50 or fewer) 3
  • 4. What Is a “High Deductible Health Plan” (HDHP)? Health insurance plan with minimum deductible of: – $1,000 (self-only coverage) – $2,000 (family coverage) Annual out-of-pocket (including deductibles and co-pays) does not exceed: – $5,000 (self-only coverage) – $10,000 (family coverage) – These are lower than Archer MSAs HDHPs can have: – no deductible for preventive care – higher out-of-pocket (copays & coinsurance) for non-network services 4
  • 5. HSA Contribution Rules Contribution to HSA can be made by either the employer or the individual, or both – If made by the individual, it is an “above-the- line” deduction – If made by the employer, it is not taxable to the employee (excluded from income) – Can be made by others on behalf of individual and deducted by the individual All contributions are aggregated5
  • 6. HSA Contribution Rules Maximum amount that can be contributed to an HSA (and deducted) = lesser of: – Amount of High Deductible or – Maximum specified in law (indexed annually by M-CPI) $2,600 (self-only coverage) - 2004 $5,150 (family coverage) - 2004 Reduced by any contribution to an Archer MSA 6
  • 7. HSA Contribution Rules Maximum Out-of-Pocket HSA Deposit Deductible Maximum (2004) $1,000 $5,000 $1,000 $1,500 $5,000 $1,500 Single $2,000 $5,000 $2,000 Coverage $2,500 $5,000 $2,500 $3,000 $5,000 $2,600 $2,000 $10,000 $2,000 $3,000 $10,000 $3,000 Family $4,000 $10,000 $4,000 Coverage $5,000 $10,000 $5,000 $6,000 $10,000 $5,150 7
  • 8. HSA Contribution Rules Contributions to Archer MSAs were limited to: – 75% of the deductible amount for family (65% for self-only plans) – Employee’s compensation or self-employment income If employer made a contribution, employee could not 8
  • 9. HSA Contribution Rules For individuals age 55 and older, additional “catch-up” contributions to HSA allowed – 2004 - $500 – 2005 - $600 – 2006 - $700 – 2007 - $800 – 2008 - $900 – 2009 and after - $1,000 Contributions must stop once an individual is eligible for Medicare 9
  • 10. HSA Contribution Rules Contributions can be made through cafeteria plans Rollovers from Archer MSAs and other HSAs permitted Employer contributions to HSA must be “comparable” for all employees participating in the HSA – If not comparable, there will be an excise tax equal to 35% of the amount the employer contributed to employees’ HSAs 10
  • 11. HSA Contribution Rules In order to meet the requirement that the employer make comparable contributions, the employer must make contributions: – which are the same amount or – which are the same percentage of the annual deductible Count only employees who are eligible individuals covered by the employer and who have the “same category of coverage” (i.e., self-only or family) Part-time employees are tested separately “Part-time” means customarily employed fewer than 30 hours per week 11
  • 12. HSA Distributions Distribution is tax-free if taken for “qualified medical expenses” – Now includes over-the-counter drugs Cannot be used to pay for other health insurance except: – COBRA coverage – Qualified long-term care insurance – Health plan coverage while receiving unemployment compensation – For individuals eligible for Medicare: Medicare (Part A, Part B, Medicare+Choice) Employee share of premiums for employer-based coverage Cannot pay Medigap premiums 12
  • 13. HSA Distributions Distributions are tax-free if taken for: – person covered by the high deductible – spouse of the individual – any dependent of the individual Spouse and dependents don’t need to be covered by the HDHP If not used for qualified medical expenses, then amount is included in income 10% additional tax if taken for non-medical expenses, except when taken after: – Individual dies or becomes disabled – Individual is eligible for Medicare Compare to 15% additional tax for Archer MSAs 13
  • 14. HSA Distributions HSA custodian must report all distributions – not required to check them for eligibility Under Archer MSA rules, the MSA custodian does not have to determine whether MSA distributions are used for medical purposes; the individual does that Given the less stringent distribution rules for HSAs, we assume Archer MSA holders will rollover to HSAs 14
  • 15. HSA Distributions Should the HSA participant keep receipts? – YES! Need to prove that deductible was met – Not all medical expenses paid out of the HSA have to be charged against the deductible (e.g. prescription sunglasses) 15
  • 16. Estate Treatment of HSAs If married, the spouse is treated as the owner In other cases: – The account will no longer be treated as an HSA upon the death of the individual – The account will become taxable to the recipient of it (including the estate of the individual) Taxable amount will be reduced by any qualified medical expenses incurred by the deceased individual before death and paid by the recipient of the HSA The taxable amount will also be reduced by the amount of estate tax paid due to inclusion of the HSA into the deceased individual’s estate 16
  • 17. Advantages of HSAs HSA accounts encourage savings for future medical expenses – When employer-sponsored coverage is lost during periods of unemployment COBRA continuation coverage other coverage – Insurance coverage or medical expenses after retirement (before Medicare eligibility) – Long-term care expenses – Out-of-pocket expenses for Medicare – Non-covered services under future coverage 17
  • 18. Advantages of HSAs Accounts are owned by the individual (not an employer) Individual decides: How much to contribute How much to use for medical expenses Which medical expenses to pay from the account Whether to pay for medical expenses from the account or save the account for future use Which company will hold the account What type of investments to grow account 18
  • 19. Advantages of HSAs Accounts are completely portable, regardless of: – Whether the individual is employed or not – Which employer the individual works for – Which state an individuals moves to – Age or marital status changes – Future medical coverage 19
  • 20. Advantages of HSAs No “use it or lose it rules” like Flexible Spending Arrangements (FSAs) – Unspent balances in accounts remain in the account and can grow through investment earnings – Encourages account holders to spend their funds more wisely on their medical care – Encourages account holders to shop around for the best value for the health care dollars 20
  • 21. Advantages of HSAs Accounts can grow through investment earnings – Many different investment options could be pursued – Individual chooses investment option that best meets their needs HDHP premiums should be cheaper than health insurance with traditional deductibles 21
  • 22. HSA Issues Prevention Rx drugs Coordination with HRAs & FSAs Individual vs. Family deductibles Substantiation 22
  • 23. Treasury Activities Initial guidance issued 12/22/03 Guidance continued monthly on – Prevention – Treatment of Rx drugs – Coordination with HRAs & FSAs – Model HSA plan document Additional guidance coming in July, 2004 Formal regulations in 2005 23