Tag Archives: Penalty

How to Avoid Health Savings Account Bank Fees

This question was submitted by HSA Edge reader Lillian. Feel free to send in your question today to evan@hsaedge.com.

I used to have an HSA account through my job but they are not offering that plan anymore, so now I have to pay a fee to keep that account open. Can I transfer that money to another account or another HSA bank where they would not charge me a fee even though my employer doesn’t offer that type of account?

Too many HSA fees

While Health Savings Accounts are a forward thinking way to save money and reduce medical expenses, the banks that provide the actual accounts have not fully caught up with the times. Their offerings suffer from poor web design, lack of tools and features, and restrictive / excessive fees. Even though HSA usage continues to increase at a rapid rate, traditional banks have not yet caught up, and avoiding fees for the HSA owner is an important part of protecting your investment. This article will review some commonly levied fees by one HSA custodian, and discuss 5 ways that you can reduce or eliminate HSA fees in your account.

Research fees structure before opening account

It is surprising how many fees there are related to HSA’s. Not just those specifically relating to your Health Savings Account, but other banking fees thrown in as well. For example, take a look at this screenshot from HSA Bank’s website describing some of their fees:

HSA bank fees

Granted, not all of these fees occur each month, and some of these are legitimate as they support costs for services. I do like how they list strategies on how to avoid the fee. However, as an HSA owner you need to look for recurring or transaction fees that affect your HSA. For example, here are some of the HSA related fees charged by that bank that directly affect HSA owners, some on every transaction!

While this bank is free to offer services they see fit, I hate being charged to access my money, so I see some of these fees as egregious and would shop around.

How to avoid HSA fees

Too many fees can add up and reduce your HSA balance over time. Plus, they are just annoying, since it is your money, and you are being nickel and dimed at every turn. As such here are some strategies to avoid or reduce Health Savings Account fees and charges.

  1. Choose low fee plans – this involves doing a bit of research before you open your HSA. While the timing of opening your HSA is important, it is also important to get the best deal possible. Search around online and talk to your bank / credit union to see what types of plans they offer. Somewhere hidden on their website is the fee schedule that you need to review. Apply those fees to your situation and compare the plans of different providers. This will insure that you are at least aware of the fees charged and can choose what is best for you.
  2. Switch HSA custodians – if you already have a Health Savings Account, you can still compare plans and switch to a new custodian if you find a better deal. This is easily done using an HSA Rollover to move funds between HSA accounts. Yes, you can have more than one HSA open at a time at different providers, and there is no tax or penalty to move HSA dollars between them. The point is you don’t have to stick with the HSA custodian your job set you up with, or the custodian where you first opened your account. Instead, do your fee research, find the best deal for you, and make a move if it makes sense.
  3. Maintain the minimum balance – one of the best parts about HSA’s is you can invest your funds tax free. However, many banks have a minimum amount needed to invest, and others levy fees if you are investing but your investment amount is under a certain minimum. Thus, if you can beef up your HSA and meet those minimums investment amounts, the monthly fees will go away forever. This might involve making an extra contribution or two to your HSA, or waiting to invest it until you have the minimum available. I recommend keeping part of your HSA in cash (not invested) at all times in case you need it for health care. Once you have that amount set aside, you can begin investing the rest.
  4. Choose cheapest options –if you look at the fee schedule above, you can see that they offer recommendations of how to avoid their HSA fees. Use this to your advantage by making choices that reduce fees charged. For example, there are a number of ways to pay for an HSA purchase. At the above bank, the associated fees are:
    • ATM Withdrawal – $2
    • Debit card purchase – $2
    • Manual withdrawal – $10
    • Online transfer – $0

    Thus, it would make the most sense to purchase HSA elgible expenses on your credit card, and do an online transfer from HSA to bank to reimburse the purchase, making it tax deductible. Playing by the bank’s rules can add up and save you a lot of money over time.

  5. Play by the rules –regardless of your bank fees, you want to be familiar with the rules of HSA’s. This will help you avoid taxes and penalties with the IRS as well as your HSA custodian. For example, excess contributions can usually be removed from your HSA before tax day without penalty. However, the HSA custodian above will charge you $25 for the pleasure. In addition, they charge $25 for a transaction correction, which consists of a change to the transaction type, amount, or tax year. By knowing what you can contribute and getting it done correctly the first time, you can avoid this $25 fee.

Note: if you need help reducing HSA bank fees, consider my service TrackHSA.com for your Health Savings Account record keeping. You can store purchases, upload receipts, and record reimbursements securely online. Besides tracking everything important, this will help you batch transactions for reimbursement and prevent mistakes that cost you money.

TrackHSA logo

Using HSA Funds Once You Turn 65 Years Old

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Penalty on Non Qualified Withdrawals

Health Savings Accounts are generally required to be spent on qualified medical expenses. Contributions you make have great tax advantages based on the assumption that you will use them for their intended purpose, which is medical care for you and your family. Deviating from properly spending the funds can result in taxes due, as well as a 20% penalty. You can read about options for cashing out your HSA, but there aren’t many ways around getting money out without paying that 20% penalty.

That all changes once you reach the age of 65 years old. Besides being eligible for Medicare (which can affect your HSA eligibility), at age 65 your HSA no longer penalizes you for taking funds out of it. This is a huge advantage is your HSA becomes much more flexible and can be spent on anything, not just qualified medical expenses. This is one reason why HSA’s are a great retirement vehicle. While always avoiding tax on medical purchases, the HSA basically converts into a 401(k) or IRA (invest pre-tax, pay taxes later) at the time you turn 65. Conveniently, this is right around retirement time, so your HSA has served you like an IRA with a great medical option on it. As you will see, some distributions after age 65 will still incur a tax, but all distributions will avoid the 20% penalty. Per IRS Form 969:

Additional tax. There is an additional 20% tax on the part of your distributions not used for qualified medical expenses. However, there is no additional tax on distributions made after the date you are disabled, reach age 65, or die.

Using HSA funds for Qualified Medical Expenses at 65

Even after reaching 65, your Health Savings Account is still the best way to pay for medical, dental, or vision care for you and your family. This is because the triple-tax advantage still exists for the HSA: pre tax funds, no tax on earnings, and no tax for medical expenses. That means that any medical care you receive after age 65 is still paid for tax free using your HSA. You should remember this and guard those HSA dollars to avoid paying the tax man more than is needed.

For this reason alone, it may make sense not to use the HSA for things other than qualified medical expenses. As you will see, while you won’t be penalized on those “other” distributions, you will still be taxed, and in turn you forfeit the ability to spend those funds tax-free on medical care. Of course, even after age 65 you can still contribute to an HSA, but at that point you may not be on an HSA eligible plan or may have begun Medicare coverage, which prevents you from contributing. So once the genie is out of the bottle and the HSA funds are gone, it may be tough to get them back in and regain tax free medical spending. The point is to protect those HSA funds since they have the special ability to pay for medical care tax free, and we know that medical spending increases as we get older.

Using HSA funds for anything at 65

Above we mention the way to play this by the book, let’s talk about the fun way to use HSA funds. Once you turn 65, you can withdraw funds from your HSA without penalty. This means you can spend them on retirement, vacations, gifts for your family, fine wine and leather-bound books, or whatever you want. Any time before age 65 doing so would incur a steep 20% penalty on this “incorrect” usage of HSA funds, but in your golden years you can spend freely and enjoy the high life with your HSA. You no longer need to spend your HSA dollars only on qualified medical expenses.

After 65, HSA funds can be spent on things other than qualified medical expenses, but these amounts are added to income, which creates a tax liability.

The only downside is that you will still owe tax on these distributions from your HSA. Any funds you pull from your HSA for non qualified medical expenses will be added to income and taxed, but I argue this makes sense given the tax history of the contribution. You were able to contribute tax-free, your earnings grew tax free, and your funds need to be spent on medical expenses to continue to be tax free. Since you are not spending them on medical expenses, they are added to income like they should have been the year you made the contribution. However, at this point you have enjoyed the advantage of tax free investment growth compounded over many years.

In addition, delaying HSA distributions until this time is beneficial as your tax rate is likely lower in retirement. This results in less of a tax hit than it would have had you been taxed at the time of contribution, likely years ago. For example, at the peak of your career your marginal tax rate may have been 30%. But in retirement, you may be in a 15% tax bracket, so you have effectively arbitraged the tax system and saved yourself significant money.

Accounting for Distributions after 65 on Form 8889

Regardless of what you spend your HSA funds on, you will need to account for it each year with the IRS. This is done with HSA Form 8889 and specifically takes place in Part II – Distributions. We will examine two scenarios and how to account for them.

If you are 65 or older and use your HSA to purchase qualified medical expenses, your Form 8889 activity will look the same as if you were not 65. Specifically, you will call out the distribution, and classify it as being spent on qualified medical spending.

The following was prepared quickly using EasyForm8889.com

Age 65 HSA distributions for qualified medical expenses

If you are 65 or older and you use you distribute from your HSA for something other than medical expenses, the treatment is a bit different. In this case, you call out the distribution amount but enter $0 for the amount spent on qualified medical expenses on Line 15. This will lead to taxable distribution on Line 16. However, there is a checkbox on 17a that you check for distributions over age 65, and line 17b backs these out from the 20% penalty.

Age 65 distribution for retirment

This way, the amount is added back to taxable income but the penalty is avoided.

Note: if you need help accounting for your HSA distributions at age 65, please consider using my service EasyForm8889.com to complete Form 8889. It asks simple questions in a straightforward way and will generate your HSA tax forms in 10 minutes. It is fast and painless, no matter how complicated your HSA situation.

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How to Determine if You Used the HSA Last Month Rule


This is a fairly common question I get from readers regarding the HSA’s Last Month Rule and how to file Line 18 on Form 8889. The question usually takes the form of:

  • “Did I use the Last Month Rule last year?”
  • “Do I owe anything for the Last Month Rule?”
  • “What should I put on Line 18 of Form 8889 where it says Last Month Rule?”

Luckily, it should be easy to figure out whether the Last Month Rule even applies to your tax return. The goal of this article is to explain how the Last Month Rule works, and then ask 3 questions to see how it applies to you.

What is the Last Month Rule?

Let’s start by defining some terms. The Last Month Rule is a “feature” of HSA’s that generally only applies to a year that you begin HSA eligible coverage. It states that if you are an eligible individual as of December 1st of a year, you are treated as an eligible individual for that entire year. This is a benefit as it allows you the option to contribute that year’s full contribution limit instead of a pro-rata amount. You get more tax free medical spending.

As an example, assume I began coverage on June 1st, 2016. Normally, I would only be able to contribute 7/12 (Jun, Jul, Aug, Sep, Oct, Nov, Dec) or just over half of the contribution limit for that year. But since I had coverage on December 1st, I am treated as an eligible individual for the whole year and may contribute up to the full contribution limit.

What is the Testing Period?

However, there is a catch. If you take advantage of the Last Month Rule and choose to contribute more than you normally could have (e.g. 12/12 vs 7/12 above), you are bound by the Testing Period to maintain that coverage for the following year. If you do not, any contribution above the 7/12 you were allowed is considered excessive and taxed and penalized on Line 18 of Form 8889 when you file your taxes. This is generally not good and should be avoided.

Please see this article for a more complete description of the Last Month Rule and Testing Period.

Determining if the Last Month Rule applies to you

First off, let’s relieve a lot of people from worry: if you had the same HSA coverage for each month in a tax year, you can put “0” on Line 18 of Form 8889. Since the Last Month Rule applies only to those who began or changed coverage, you can ignore it and likely go onto something else more enjoyable.

If you had consistent HSA eligible insurance for each month of the year, the Last Month Rule does not apply and you can put “0” on Line 18 of Form 8889.

On the other hand, if you began or changed HSA coverage this year, let’s pose three “yes” or “no” questions to help determine if the Last Month Rule applies to you. You must answer “yes” to the following 3 questions to be eligible to use the Last Month Rule. Answering “no” to any of the following means you can only contribute the pro-rata contribution amount for the months you were HSA eligible.

1) Were you an eligible individual (have HSA eligible coverage) on December 1st of the tax year?

Answering “no” precludes you from using the Last Month Rule as it is a base requirement. This rules out people who, for example, had coverage from January – November of a year, or had coverage from February until August of a tax year. You at least have to have coverage in December to be eligible for the Last Month Rule.

If you answered “yes”, then you may be eligible to use the Last Month Rule, read on.

2) You were HSA eligible (had HSA coverage) for only part of the year?

Answering “no” means you had coverage for the full year, so by definition you can already contribute the HSA maximum contribution limit. You had coverage for 12 months, so can contribute 12/12 or 100% of the contribution limit for the year. You don’t need the Last Month Rule’s help. If this applies to you, put “0” on line 18 of Form 8889.

If you answered “yes”, you likely began coverage mid-year. Perhaps you got a new job and had HSA qualified starting on April 1st, so 9/12 months of the year. Or you had coverage for January through April, then stopped, then had coverage for November and December. If this sounds like your situation, this means that you have the option of using the Last Month Rule for that year. To actually use it, move on to question #3.

3) Did you contribute more than you would otherwise be allowed?

Answering “no” means you contributed less than or equal to your contribution limit based on your months as an eligible individual. So if you had HSA coverage for 5 months, you are allowed to contribute up to 5/12 (41.6%) of the contribution limit without using the Last Month Rule. Doing so plays it safe and avoids any of the requirements or risk of penalty associated with the Testing Period.

Answering “yes” sounds like, “I had HSA coverage for 7/12 months but I contributed the maximum contribution limit using the Last Month Rule”, or “I had coverage for 3/12 months (Oct / Nov / Dec or 25%) but contributed 1/2 (50%) of the maximum contribution limit.” In both of these scenarios, you contributed more to your HSA than you would generally be allowed. This is allowable, as you leveraged the Last Month Rule to make an increased contribution, but remember it has strings attached.


If you answered “No” to any of the 3 questions above, you cannot use the Last Month Rule. You will need to contribute your pro-rata contribution limit based on the number of months you were HSA eligible. You can also put “0” on Line 18 of Form 8889.

If you answered “Yes” to all 3 questions above, you used the Last Month Rule and contributed more than you generally could have. This is allowable but remember you need to maintain HSA coverage for the next year due to the Testing Period. For the current year, you can put 0 on Line 18. If you maintain that HSA coverage through the following year, you will also put “0” on Line 18 of that year’s Form 8889, pass the Testing Period, and hopefully never worry about the Last Month Rule again. Only if you don’t maintain coverage (i.e. fail the Testing Period) will you need to calculate a penalty for Line 18, which will increase your taxable income and add a penalty to your 1040 return.

Note: if this is super confusing, please consider using my service EasyForm8889.com to complete Form 8889. It asks these questions in a straightforward way and will generate your HSA tax forms in 10 minutes. It is fast and painless, no matter how complicated your HSA situation.

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