It's not how much money is in the account that matters. If you made contributions or withdrawals in 2016, those must be reported on form 8889, and that form isn't ready yet. If you leave the form out, you WILL get a letter and a bill for taxes and penalties, because if you don't use the form to say that you used the withdrawal for qualified medical expenses, the IRS will assume the withdrawal were not qualified and will charge you tax on them.