With no excess contribution having been made and if the distribution is treated as constituting a regular distribution, the distribution can be deposited back into the HSA within 60 days as a rollover (provided that this would not result in a violation of the one-rollover-per-12-months limitation). The challenge will be convincing the HSA custodian that the distribution cannot have been a return of excess contribution because no excess contribution had actually been made. If they can be convinced, they should recode the distribution as a regular distribution so that the 2024 Form 1099-SA has the appropriate coding to indicate a regular distribution. With the 2024 Form 1099-SA showing a regular distribution, it will be a simple matter in 2024 TurboTax to indicate that this distribution was rolled over.
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