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IRS Issues 2018 Version of Publication 969 on HSAs, HRAs, Health FSAs, and MSAs

EBIA  

· 5 minute read

EBIA  

· 5 minute read

IRS Publication 969 (Health Savings Accounts and Other Tax-Favored Health Plans (for use in preparing 2018 returns))

Available at https://www.irs.gov/pub/irs-prior/p969–2018.pdf

Publication 969 has been updated for use in preparing 2018 tax returns. This publication provides basic information about HSAs, HRAs, health FSAs, Archer MSAs, and Medicare Advantage MSAs, including brief descriptions of benefits, eligibility requirements, contribution limits, and distribution issues.

The 2018 contribution limits, deductible requirements, and out-of-pocket maximums for HSAs and Archer MSAs, and the limit on health FSA salary reduction contributions for plan years beginning in 2018 have been provided. A note explains that the 2018 HSA contribution maximum for individuals with family coverage was lowered to $6,850 and then restored to $6,900. Taxpayers who received distributions of excess contributions because of the temporary limit reduction are informed that they may recontribute those distributions without adverse tax consequences (see our Checkpoint article). The limits and thresholds for HSAs and HDHPs for 2019 are also provided (see our Checkpoint article) but not the 2019 amounts for Archer MSAs or health FSAs (see our Checkpoint article). The Publication has been updated for the deadline for making HSA and Archer MSA contributions for 2018 (April 15, 2019), which is also the deadline for the HSA recontributions noted above.

EBIA Comment: Publication 969 provides a convenient overview of the basic features of various consumer-driven health care vehicles, but it is not intended to address the many design and administrative details that employers and their advisors need to know, and should not be relied upon without reference to other sources. We note that the “Reminders” section at the beginning of the 2018 Publication concludes with a statement that “the following rules” apply to health FSAs. That appears to be a holdover from the previous year, and should not be read as suggesting that the remainder of the Publication applies to health FSAs (which is not correct). For more information about HSAs, HRAs, Archer MSAs, and Medicare Advantage MSAs, see EBIA’s Consumer-Driven Health Care manual. For more information about health FSAs, see EBIA’s Cafeteria Plans manual. You may also be interested in our webinar, “What’s in Store for HRAs? Reassessing Opportunities in Light of New Proposals” (recorded on 1/24/2019).

Contributing Editors: EBIA Staff.

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