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November 23, 2021
Question

Am I allowed to fund an HSA if I have a retirement HRA?

  • November 23, 2021
  • 2 replies
  • 0 views

I am age 62. At retirement, my employer opened a "retirement HRA" (not a limited-purpose HRA) for me and funded it.  I still have the HDHP and also an HSA that was funded before retirement.  Am I allowed to fund my HSA, on my own, until age 65?  I believe not, based on page 5 of IRS pub 969 and  page 5 of IRS revenue ruling 2004-45 for Section 223, but would like other opinions.  It appears to not be entirely clear.  Thank you.

    2 replies

    JL59Author
    November 23, 2021

    I should have added to my question:  Am I missing something?  If you can, please direct me to a citation that says I can contribute.  Thank you.

    Employee
    November 24, 2021

    You are correct, you can’t make new contributions to an HSA unless you are covered by a qualifying HDHP and no “other” coverage.  The HRA counts as other coverage and disqualifies you from contributing to an HSA.  

    I believe the HRA must be renewed each year.  Any unspent funds in the HRA may roll over to the next year or may be returned to the employer but can not be distributed to you for any reason except reimbursement of qualified medical costs.   If you declined to participate in the next plan year—and you are still covered by a qualifying HDHP—you could resume HSA contributions.  

    January 12, 2025

    Please refer to publication 969. It appears that you would be eligible to continue contributing to your HSA because the HRA is only for retirement. This of course depends on if you are currently retired or not.