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from PUB 969

nses.
Qualified medical expenses are those incurred by the following persons.
1. You and your spouse.
2. All dependents you claim on your tax return.
3. Any person you could have claimed as a dependent on your return except that:
b. The person had gross income of $5,050 or more;

 

Your son is too old to be claimed as a qualifying child dependent. Thus, to be claimable (you don't actually have to claim him)  as a dependent, the qualifying relative tests must be met. The relationship test is met. The gross income test is waived. The support test requires you to pay more than 50% of his support.

 

if you meet the support test, those are qualifying medical expenses for purposes of paying them out of the HSA. Each year, you must review the support test to see if you pay more than 50%,  

 

If you did/do not meet the requirements, any withdrawal to pay his medical expenses would be subject to regular income taxes and a 20% penalty.