Using HSA Funds to Pay Dental Premiums. (Age <65)

[dblatz]

I am 61 years old and retired a year ago and continued my dental plan under my former employers early retiree COBRA dental plan. I pay the full dental premiums for the same plan I was using when employed and am able to continue this coverage until I am 65. Would my premiums qualify as a qualified medical expense per the following IRS guidelines (#2 below) as my dental plan is considered a continuation COBRA plan?

You cannot treat insurance premiums as qualified medical

expenses unless the premiums are for:

1. Long-term care (LTC) insurance,

2. Health care continuation coverage (such as coverage under COBRA),

3. Health care coverage while receiving unemployment compensation under federal or state law, or

4. Medicare and other health care coverage if you were 65 or older (other than premiums for a Medicare supplemental policy, such as Medigap).

[Mike9241]

You can pay those premiums using your HSA. 

[Opus 17]

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@Mike9241 wrote:

You can pay those premiums using your HSA. 

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I agree, but I don't see this spelled out in Publication 969.  I can offer this logic:

You can't contribute to an HSA if you have "other coverage" for medical costs on top of your HDHP.   However, certain types of insurance don't count as "other coverage" that would disqualify you, including accident coverage, disability insurance, and dental insurance.

Since you can have dental insurance and still contribute to an HSA, I think the logic would be that it does not count as premiums you can't pay from an HSA, even though it is not specifically mentioned in the publication. 

[dmertz]

If you are paying the dental insurance premiums to your former employer under COBRA, they are for healthcare continuation coverage and are qualified medical expenses for HSA purposes.

[TomK2023 · Accepted solution]

Yes, you may use funds from your HSA to pay for your dental insurance premiums as a medical expense since the premiums are paid for health care continuation coverage (such as coverage under COBRA).

Please see IRS Pub. 969 - Health Savings Accounts and Other Tax-Favored Health Plans for additional information (pg. 9)