@dmertz
As usual, your tax research is spotless. Yes, the instructions are just as you say - the excess employer contributions are "homeless" in that the IRS doesn't address them any more than they address what to do with excess HSA contribution carryovers on the 8889.
The thing is about the instruction for Line 1h is that they are explicitly for retirement plans, as I am sure you saw. On the one hand, you could argue that the HSA is one of the best retirement plans around. On the other hand, I saw somewhere a court ruling (Ohio?) about HSAs, that they were not to be considered retirement plans because the IRS lists all the retirement plans somewhere (sorry, memory fails me), and HSAs were not in the list. The court case was about dividing property in a divorce case, and in that state, retirement plans were divisible between the two parties, but the HSA was considered the sole property of the party that owned the HSA. I wish I remembered if they said anything about IRAs; it would seem that they would follow the route of the HSA and not that of the retirement plan.
I will add this to the list of things to consider for processing HSAs; thank you for the observation.
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