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New Member
posted Mar 6, 2021 3:51:00 PM

How can I calculate the Earnings on Excess for an HSA Overcontribution. The NIA formula result seems high for a $76 overage.

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1 Best answer
Expert Alumni
Mar 8, 2021 4:55:30 PM

You don't need to calculate the earnings on an excess contribution to your HSA; let the HSA custodian do it.

 

When you call the HSA custodian (or do the form online) to report the request to withdraw the excess contribution, this will start a process at the HSA custodian. They will calculate the amount of earnings, and then send you the excess plus the earnings out of the HSA. This will be reported on a form 1099-SA.

 

Note that for 2020, the excess contributions will be added to line 8 of Schedule 1 (1040), if the excess was due to the amount with code W in box 12 on your W-2. So the excess is taxed in 2020.

 

However, you will not get the 1099-SA with the earnings until next year, to add it to your 2021 tax return.

 

So, ask the HSA custodian to withdraw excess (specifying the excess amount only); they will take care of the earnings - since some of the earnings belong to 2021, the IRS lets you defer taxes on all the earnings until 2021.

24 Replies
Expert Alumni
Mar 8, 2021 4:55:30 PM

You don't need to calculate the earnings on an excess contribution to your HSA; let the HSA custodian do it.

 

When you call the HSA custodian (or do the form online) to report the request to withdraw the excess contribution, this will start a process at the HSA custodian. They will calculate the amount of earnings, and then send you the excess plus the earnings out of the HSA. This will be reported on a form 1099-SA.

 

Note that for 2020, the excess contributions will be added to line 8 of Schedule 1 (1040), if the excess was due to the amount with code W in box 12 on your W-2. So the excess is taxed in 2020.

 

However, you will not get the 1099-SA with the earnings until next year, to add it to your 2021 tax return.

 

So, ask the HSA custodian to withdraw excess (specifying the excess amount only); they will take care of the earnings - since some of the earnings belong to 2021, the IRS lets you defer taxes on all the earnings until 2021.

New Member
Mar 9, 2021 3:48:58 PM

Perfect! Thanks for the great explanation. 

New Member
Jan 11, 2022 8:21:56 AM

I went over this past year by $136.50. On my HSA Excess Contribution form, I put that amount on my excess amount. Now, do I just leave the “earnings on Excess” blank or put $0 there?? The answer I am replying to said to let the HSA custodian calculate the earnings, but when I called HSA, they told me they can’t tell me what to put there. So do I just leave the earnings on excess blank?? Thank You in advance for your response!!

Expert Alumni
Jan 11, 2022 12:36:23 PM

The HSA custodian will tell you what to put there...but next year. That is, while the excess contributions are reported as Other Income in the current tax year (TurboTax does this for you automatically), the earnings will be reported on a 1099-SA that the HSA custodian will send you for next year.

 

So if the current tax year is 2021, then sometime between now and early 2023, the HSA custodian will send you a 1099-SA reporting the earnings on the excess contributions, and you will add this to your 2022 return.

 

Please do NOT try to add the earnings on your current year return, and please do not try to calculate the earnings yourself...

 

" HSA Excess Contribution form" - what form is this? This is not an IRS or a TurboTax form, is it?

Returning Member
Feb 21, 2022 8:38:59 AM

HSA Bank has a form I have to fill out in order to process the overcontribution correctly. One of the boxes is 'Earnings on Excess: $___'. The lady I was talking to said that needs to be filled in. I asked her if she could help me calculate that and she said that they can't and that a tax advisor has to do that... so here I am.

Returning Member
Feb 21, 2022 8:44:35 AM

You say 'next year.' Maybe I waited too long but hopefully not. I overcontributed to mine back in March 2021 and now I am taking time to try to fix it now, yet the lady still told me she can't tell me what to put in the box.

Expert Alumni
Feb 21, 2022 9:16:40 AM

The HSA financial institution should be calculating the interest/earnings on the amount of the distribution.  It's extremely unusual for them to expect you to do it.  They know what the earnings are and how to calculate them - believe me.  My advice would be to fill out the form and do not enter the earnings, add a note for them to insert the earnings after it has been calculated.  

 

According to our tax expert @dmertz, here is the link to calculate the earnings if you really need to. 

  • CFR 1.408-11 describes the required calculation for determining the earnings on your HSA withdrawal
    • Net Income=Contribution×(Adjusted Closing Balance−Adjusted Opening Balance)/Adjusted Opening Balance.

​​​​​​​@Bradley_C

Level 15
Feb 21, 2022 11:35:22 AM

I agree that it's odd that this major HSA custodian would require you to do the calculation unless the contribution was made to an HSA at a different custodian and was subsequently transferred.  In that case the receiving HSA custodian generally would not know when or how much was contributed at the old custodian, so could not do the calculation.

 

The instructions for Form1099-SA instruct the preparer to use the calculation described in CFR 1.408-11 to determine the amount of earnings attributable to the amount being returned.  It's lame of them to push this responsibility on to you, particularly when you don't necessarily know how the attributable earnings might change between the time you prepare the form and the time the distribution is actually made.  To be done properly so that the distribution conforms to the law, the calculation really needs to be done at the same time the distribution is being made.

Level 2
Apr 14, 2022 10:24:44 PM

After waiting on hold for well over an hour with HSA Bank, I got the exact same answer from them - "We can't tell you what to put on the form.  You have to consult a tax person."  Yet here in this community thread, the tax experts are saying that the HSA custodian is the only one who CAN figure it out for you and they do that at the time the excess contribution is distributed.  My inclination is to leave that box blank because my copious research on this topic has not yielded a clear answer.  The HSA Bank phone representative told me that it is okay to leave the box blank, but who knows what the person who processes the form will think of that.

Level 2
Apr 14, 2022 10:57:38 PM

Another thing that I find confusing about this topic is the earnings on excess vs the excise tax / penalty.  Are they actually two different things or are they two terms for the exact same thing?

 

Many people online seem to be mistaken when they say that, to paraphrase, "Earnings on excess is 6% of the excess amount."  Even the HSA Bank representative to whom I spoke a little while ago mentioned the 6% as probably being used to calculate the earnings on excess amount.

 

However, per IRS Publication 969, the 6% number seems to be a penalty amount rather than the earnings on excess:

 

Generally, you must pay a 6% excise tax on excess contributions. See Form 5329, Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts, to figure the excise tax. The excise tax applies to each tax year the excess contribution remains in the account.

 

You may withdraw some or all of the excess contributions and avoid paying the excise tax on the amount withdrawn if you meet the following conditions.

 

  • You withdraw the excess contributions by the due date, including extensions, of your tax return for the year the contributions were made.
  • You withdraw any income earned on the withdrawn contributions and include the earnings in “Other income” on your tax return for the year you withdraw the contributions and earnings.

 

If I understand it correctly, 6% is the excise tax that is assessed each year that the excess remains in the account.  If you want to avoid paying the excise tax, you have to withdraw the excess from the account before the income tax filing deadline.

 

And still, after sorting out the excise tax part of this equation, I have no idea how to calculate the earnings on excess!!

 

 

Level 15
Apr 15, 2022 3:49:46 AM

The penalty on an excess contribution is the %6 excise tax.

 

When entering into 2021 TurboTax an excess HSA contribution made for 2021 and returned in 2022, when TurboTax tells you that you have made an excess contribution and asks how much of the excess you will ask to be returned, that's all you enter.  You don't need to know the investment gain or loss at this point, TurboTax isn't asking for that here. 

 

If you've received a Form 1099-SA reporting the return of the excess contribution, code 2 in box 3, box 2 will be the difference between the amount of excess contribution that you requested be returned and the amount distributed, but not less than zero.  If box 2 shows a positive number, upon entering that Form 1099-SA into TurboTax will include the box 2 amount on Schedule 1 line 8e.  If box 2 contains a zero or is blank, the form is indicating that there was no gain or that there was a loss.

Not applicable
Jan 2, 2023 9:53:11 AM

Did leaving the excess earnings box blank work for you? 

 

I am having the same issue with HSA Bank. I have spent a crazy amount of time trying to figure out how to do the calculation correctly but I just don't trust myself. I am at the end of my rope so I am sending in the form with the box blank and hoping for the best. I may pay for TurboTax full service this year to help me.

Expert Alumni
Jan 9, 2023 11:33:51 AM

The formula for determining the amount of the earnings from the excess contribution is as follows:

 

Net Income = Contribution x Adjusted Closing Balance - Adjusted Opening Balance

                                                               Adjusted Opening Balance

 

The "adjusted opening balance" is the fair market value of the HSA at the beginning of the computation period plus the amount of any contributions made to the HSA during the computation period (including the contribution that is distributed as a returned contribution).

 

The "adjusted closing balance" is the fair market value of the HSA at the end of the computation period plus the amount of any distributions made from the HSA during the computation period. 

 

The "computation period" is the period beginning immediately prior to the time the particular contribution is made to the HSA and ending immediately prior to the removal of the contribution being returned. 

 

If you prefer, you can follow-up with additional information regarding how you computed the excess earnings from the over contribution.  As a reminder, in any follow-up response, do not include personal identifiable information.  

 

@Anonymous

 

Level 2
Mar 1, 2023 1:29:46 PM

I used the formula above to calculate the earnings, but I am not sure where to put that into TurboTax. TurboTax knows the amount of my excess contribution, but it never asks me about the *earnings* on that excess contribution. When I leave "step-by-step" and go into the form view, it will not let me type into Form 8889 boxes 14a and 14b where it seems like that information should go per-IRS instructions. 

Expert Alumni
Mar 1, 2023 1:53:04 PM

"TurboTax knows the amount of my excess contribution, but it never asks me about the *earnings* on that excess contribution."

 

No, TurboTax does not ask this, because it can be found on a 1099-SA that the HSA custodian sends you. This 1099-SA will have a distribution code of '2' in box 3, to report the amount of the earnings on the excess contributions that you will have to add to your income.

 

As I noted way above, you normally just let the HSA custodian calculate the amount of earnings, although dmertz did allude above to a circumstance in which the HSA custodian might not be able to do this. Still, the normal process is for the 1099-SA with the code of '2' to come from the HSA custodian, who has already calculated the earnings.

 

Is this a problem with this, like you don't have a 1099-SA with a code of '2'?

Level 2
Mar 1, 2023 2:39:24 PM

Thank you for getting back to me! This is SOOOO helpful. 


I do not have a 1099 from HSA Bank because I haven't made any withdrawals from the account (no medical payments and I haven't made the withdrawal of excess funds yet). HSA Bank's form for Excess Contribution Removal asks the account holder to list the excess contribution *and* the earnings on that excess contribution--thus the *account holder* needs to do that calculation. HSA Bank is the most lazy and incompetent custodian ever. 

I followed your tips by pretending I had a 1099-SA with the excess contribution + earnings that I calculated, and then the 8889 form looks great. I will contact HSA Bank, get them to withdraw the funds, get a 1099-SA, and then finish my taxes with that 1099-SA rather than my guess of what it will say. 

Level 2
Mar 1, 2023 3:04:50 PM

My HSA account was transferred, but it seems HSA Bank refuses to tell anyone the earnings on the contributions. The excess contribution form asks *you* to also include what the earnings on that excess contribution was. 
You are completely right about the timing of the withdraw and the earnings. Because of this, I moved my whole balance to cash  (sold all equity investments which move around daily). I know the interest is paid on the last day of the month, so I am processing the excess contribution withdraw form on the first of the month when I know what the earnings are. Really is such a pain that I shouldn't have to do. 

Expert Alumni
Mar 1, 2023 5:22:12 PM

So are you OK now?

Level 2
Mar 1, 2023 7:30:12 PM

Thanks for checking back in--that is very kind of you!

I do have one more question as I stepped away from it. I had read your posts about the delayed sending of the 1099-SA which you wrote March 8th 2021 and Jan 11 2022 where you said that the 1099-SA will not come until the next year.  So I should not wait for them to send an updated 1099-SA because they probably won't send it until after the tax deadline. I can follow the way Turbo Tax is set up: just put in the excess contributions this year and then when I do my 2023 taxes I will pay income tax on my earnings on excess contributions?

From my reading of the IRS instructions I thought I had to pull the excess contributions and their earnings out this year to avoid the 6% penalty but the way Turbo Tax is set up I cannot do that unless it was on the 1099-SA (which it wasn't). If I understand your point in your earlier message, because the earnings are withdrawn in 2023 this is a 2023 taxable event?

Thanks again, I really appreciate the fabulous customer service and detailed attention you are giving this issue for us all. 

Expert Alumni
Mar 2, 2023 11:29:31 AM

Think about the sequence of events...

  • You discover that you made excess HSA contributions while doing your 2022 tax return in early 2023.
  • TurboTax tells you how much to withdraw (because you should not withdraw it before you know how much to withdraw)
  • The IRS allows you to "cure" the excess by withdrawing it by the due date of the 2022 return as extended (generally, April 15, but April 18, 2023 - this year).
  • So your excess is busy earning money in the latter part of 2022 (you usually don't have an excess until late in the year), and in the early part of 2023 
  • You need to report the earnings as income, but you don't know what the real amount is until 2023.
  • Hence, no matter when you get the 1099-SA, you need to report the earnings for tax year 2023 (a rare case of reporting 2022 income in tax year 2023 - because 2022 income and 2023 income are lumped together)

So, depending on the HSA custodian and when you asked for the withdrawal of the excess, you might get the 1099-SA in the first half of 2023, late in 2023, or even in early 2024.

Level 2
Mar 2, 2023 12:34:00 PM

Awesome! I can finish these taxes today then and am fully confident I did it right! I went back to read the 8889 instructions and it does say to avoid the penalty "you also withdraw any income earned on the withdrawn contributions and include the earnings in “Other income” on your tax return for the year you withdraw the contributions and earnings."

I am withdrawing that in 2023 so it will be on my tax return for 2023 (which is not the tax return I file in 2023).

Thanks for making my tax season, Bill!

Level 1
Mar 31, 2023 12:24:32 PM

Hi! 

Similar situation here, but due to the stock market not doing so well in 2022, I actually calculated loss on my excess contribution amount. 

Do I report negative $# on 2023 tax return? I know I will get 1099-SA and will just input the number that is written on there but wanted to see if that's possible.

 

Very similar situation as OP. My original custodian refuses to calculate the earning portion (their CS was really bad from the beginning) and my new custodian asked for the earning amount before it was transferred to them. 

Expert Alumni
Mar 31, 2023 1:19:43 PM

On the 1099-SA that you should get, the amount of excess contributions will appear in box 1, and the earnings should appear in box 2. 

 

I believe that the amount in box 1 will have been adjusted for the negative amount of earnings. 

Level 1
Mar 31, 2023 1:25:49 PM

Hm..

so I am inputting the excess contribution amount again for 2023 tax return?

I am already getting that amount withdrawn from my current HSA custodian and paying income tax on that portion for the 2022 tax return.

 

I thought I only worry about the box 2 portion of 1099-SA on my 2023 tax return.....