My HSA is no longer employer-sponsored, so it therefore managed by some other "custodian" party or company which charges a monthly $4 fee for use of their service. I believe that fee is not considered a qualified medical expense, but I want to make sure.
Is a monthly fee to manage an HSA a qualified medical expense?
The following side notes can be ignored as it's unimportant to my question: I do not find this clarification in the IRS list, nor in the custodian company list, yet I have received a 1099-SA with distributions totaling those fees, so for anyone out there reading this question who manages such FAQs/lists, it would be great if you could update your FAQs. Another aside, regardless of the answer about HSA fees actually being qualified medical expenses, it seems they should be considered qualified because an HSA to some extent contains medical records, and, as well, managing an HSA can be viewed as indirectly connected getting proper medical care in the future (consider stopping an HSA and taking a penalty and being with less than desired medical expense money at such a future time, as just one example). It seems silly that this is not a qualified expense. I'm certainly not seeing the money, yet someone has my entire HSA funds which, I'm guessing, are being invested and used in some manner. For that participation, someone else is getting the fee for managing those funds. I hold out I may be missing an important nuance here (please let me know if you think so), but paying a small fee for an HSA seems strongly connected with managing a positive healthcare plan overall, including HSA. Just my current thinking. Thanks for any answers!
The fee is not a medical expense but it is neither a distribution taxable to the recipient.
You go on to state " I have received a 1099-SA with distributions totaling those fees"
The advice is the custodian has filled out the 1099-SA wrong and reported those to the IRS as distributions. The custodian needs to provide a corrected 1099-SA.
You have to followup with the custodian.
If the custodian refuses to correct the 1099-SA get that information in writing from then and you would need to retain the supporting documentation that they are refusing to correct the 1099-SA.. You could then paper file using your corrected distribution amount(amount not including the fees) and include a letter of explanation why your box 1 reporting to IRS is different from the custodians. Clearly state that the distributions were fees taken directly by the custodian and were not distributions made directly to you the recipient, (Account statements would support those were taken as fees and not distributions) and are expenses not to be reported in box 1 of form 1099-SA as distributions.