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Posted by Y on October 5, 2009, 12:51 pm
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Cathy wrote:
> I currently have an HDHP (High-deductible health plan) through my
> employer - single coverage with a $2,500 deductible per year. I make
> a weekly contribution through payroll (via cafeteria plan) to my
> Health Savings Account (HSA). I understand my maximum contribution
> for 2009 is $3,000. The HSA is through a local bank.
>
> For 2008, they reported my total contributions to the IRS on a Form
> 5498-SA and also reported by distributions on a Form 1099-SA. And, I
> did not have any issues with the information that was reported on
> these forms. And, in 2008, I generally paid for all of my medical
> expenses out of my everyday, regular bank account and then reimbursed
> myself before the end of the year from my HSA account - just so I
> didn't have to keep the receipts for 10 years to prove I actually had
> incurred the expenses 10 years previously! And, given the situation
> I'm facing in 2009, I think it is probably a good idea to continue to
> do it this way - if possible!
>
> Ok, so in 2009, I had a medical bill that had not been processed by
> the insurance company correctly and, despite receiving many
> statements from the medical provider, I did not pay the bill as I was
> expecting the insurance company to pay almost all of the bill (all
> except about $3.00). Well, I forgot why I hadn't paid this bill and
> got a nasty gram from the medical provider saying my account would be
> turned over to collections within 10 days if it was not paid. So,
> just to satisfy them, I went ahead and paid the bill directly out of
> my HSA account. A few days after I'd paid the bill, I remembered why
> I hadn't paid it previously - and I'm sure the provider would have
> put a delay on the collections action had I called them explaining
> the reason I had not paid the bill. (I generally refuse to pay
> medical providers until insurance has processed it correctly and paid
> what they were supposed, but this one slipped past me. Based on past
> experience, it is like pulling teeth to get refunds from medical
> providers if they have been overpaid by me.)
>
> So, several weeks ago, the insurance company finally processed the
> claim correctly. And, about 2 weeks ago now, I received a refund
> check in the mail from the medical provider - surprisingly!
>
> My question is: This money should go back into my HSA account -
> correct??? I believe that I understand that if the bank is notified,
> they can mark my deposit in their system so that it is not included
> in the Form 5498-SA reporting for my 2009 contributions - which makes
> sense to me - otherwise, there would be, in theory, a distribution
> included on the 1099-SA that was actually NOT for a medical expense
> and subject to tax and penalty on my 1040. However, when I end up
> spending this money, I presume that it will be included in the Form
> 1099-SA that shows my distributions for the year - is this correct??
> I could potentially see my 5498-SA showing $3,000 for 2009 and my
> 1099-SA showing $3,000 plus this refund amount. Would that look
> funny or cause questions? Even though I have met my deductible for
> 2009 of $2,500, I still have out of pocket expenses for dental and
> eyeglasses that could easily eat up the $500 plus that could be
> available in the account for the year.
>
> I could see this scenario continuing on for me during the rest of
> 2009 as I have to pay for my prescriptions up front even though my
> deductible has been met and then wait for a refund from the insurance
> company. So, if I paid for the prescriptions from the HSA account
> and then got a refund .... it appears to me that the 5498-SA and
> 1099-SA reporting could get all screwed up if I am not on top of
> this. Or, am I just thinking way too hard about this? And, maybe I
> just have to leave it to the bank to screw it up and then try to
> convince them that their figures are wrong after they issued the year
> end forms?
>
> If anyone has any guidance for me, it would be most appreciated.
>
> Cathy H.
> Ellsworth, KS
See IRS Notice 2004-50 at:
http://www.irs.gov/irb/2004-33_IRB/ar08.html#d0e1614
See Q&A 37 about redepositing incorrect withdrawls (a similar
circumstance to yours), but also see Q&A 76, which indicates that the
trustee is not required to accept this redeposit.
Many HSA Custodians DO accept these redeposits, and often have a form
for this specific purpose.
HTH
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