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Exceptions to the HDHP requirement for HSAs

Can you be covered under a non-HDHP plan and still contribute to a health savings account? Likely not, but there are exceptions.

Certain types of coverage are permitted alongside an HDHP without affecting your HSA eligibility. This article covers those exceptions. (For the core eligibility checklist, see Eligibility requirements to open an HSA.)

The general rule

If you're covered under someone else's non-HSA-eligible High Deductible Health Plan, you cannot open an HSA.

Permitted additional coverage

The IRS allows certain types of coverage that do not disqualify you from opening or contributing to an HSA:

  • Insurance for something non-medical (e.g., workers' comp, home insurance, auto insurance)

  • Insurance for a specific disease or illness (e.g., a cancer policy)

  • Hospitalization insurance that pays a fixed amount per time period (e.g., per day or week)

  • Coverage under an Employee Assistance Program

  • Discount cards for health services

  • Insurance for dental, vision, long-term care, accident, or disability

Source: IRC Sec. 223(c)(1)(A)(ii)

VA medical benefits

Effective January 1, 2016, the Surface Transportation and Veterans Health Care Choice Improvement Act (H.R. 3236) permits veterans enrolled in an HDHP — without other disqualifying coverage — who have a service-connected disability to make or receive HSA contributions, regardless of when they received VA benefits.

Source: IRS Notice 2004-50, Q&A Q-5

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