"Yes, the beneficiary (the estate) is permitted to pay out of the HSA any medical costs incurred BEFORE the date of death but paid after the date of death; these amounts reduce the amount of income that the beneficiary must declare upon the date of death of the HSA account owner."
Only a beneficiary other than the estate (i.e., a person) can do this. § 223(f)(8)(B)(ii)(I)
