dmertz
Level 15

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Yes, you can reimburse your qualified medical expenses incurred in 2018 (if fact, any incurred after the establishment of HSA #1) from either of the HSA accounts without doing any rollovers or transfers.  Since you had an nonzero HSA balance at some point in the 18-month period prior to opening HSA #2 (you apparently never had a nonzero balance in HSA #1), your HSA establishment date of HSA #1 carries over to HSA #2.  See IRS Notice 2008-29 Q&A-41:

 

https://www.irs.gov/pub/irs-drop/n-08-59.pdf

 

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