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January 19, 2005

HSAs Unlock New Designs for Health FSAs

Health Savings Accounts (HSA) are designed to bring consumerism to health care by engaging participants in the decision making process. These types of accounts are rapidly growing in popularity because they slow the cost increase of employer benefit plans, provide a new vehicle for retiree health and bring many individuals affordable health care options.

When employers offer HSAs under a cafeteria plan, they also provide both company and employee tax savings. However, these configurations of HSAs and FSAs do come with several design requirements in order for participants to be eligible to participant in an HSA.

HSA participation is limited to individuals who enroll in a high deductible health plan with a minimum deductible of $1,000 for single and $2,000 for family coverage. There can be no other coverage than the expenses attributable to the deductible.

A trend Infinisource has noted is employers maximizing their savings by offering the new HSAs and designing them in conjunction with limited, single, or post-deductible FSAs. This plan design maintains the tax advantages previously enjoyed, and perhaps expected by employees when they elected a Health FSA. Care must be taken in plan design to ensure these innovative Health FSA plans will allow the individual to qualify for an HSA.

The chart below shows how these new plan types might be designed.

Single Coverage Health FSA

Generally, FSAs cover expenses incurred by all eligible dependents.  It is not required for an individual to enroll their spouse or children in order to receive reimbursement for their medical expenses. Employers could offer ?single only? FSAs so that individuals can avoid disqualifying their spouse from being an eligible individual for an HSA.

Post-Deductible Health FSA

An individual could not be reimbursed for any medical expenses incurred before the minimum annual deductible is satisfied.  The deductible for the FSA does not have to be the same as the deductible for the HDHP, however the HDHP cannot pay anything until the HDHP deductible has been satisfied.  If the HDHP and the FSA do not have identical deductibles, contributions to the HSA are limited to the lower of the deductibles.  Although the deductibles of the HDHP and the other coverage may be satisfied independently by separate expenses, benefits cannot be paid before the minimum annual deductible has been satisfied.

Limited-Purpose Health FSA

An individual could still be eligible for an HSA if the coverage is limited to preventive care expenses which includes the following:

  • Periodic health evaluations, including tests and diagnostic procedures in connection with routine examinations such as annual physicals
  • Routine prenatal and well child care
  • Child and adult immunizations
  • Tobacco cessation programs
  • Obesity weight loss programs
  • Screening services

Preventive care generally does not include any service or benefit intended to treat an existing illness, injury or condition.  Keep in mind that over-the-counter (OTC) drugs are not listed as permitted coverage items unless the drug constitutes preventive care and satisfies Code Section 213(d) requirements.

Combined Post-Deductible Health FSA

Individuals could be reimbursed for their dental, vision or limited medical expenses once their HDHP deductible has been satisfied for any 213(d) medical expense.

For more information on HSAs, FSAs and other employee benefit administration and compliance issues please call Infinisource at 800-779-6384 or send an email to solutions@infinisource.net.

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