3005852
I made an excess contribution of $177 in 2022. When I realized it in mid-March, I contacted my HSA administrator to make a “distribution of excess contribution.”
The problem is that my employer changed HSA administrators in 2023 and planned to do a bulk transfer of all employee accounts between March 15th and April 5th..
My distribution did not get processed by the former HSA admin before the transfer took place, so my account went to $0 and was closed. Thus, it can no longer be distributed through them.
The new HSA admin refuses to process the distribution, even if I provide my 2022 Form 5498-SA or other statements from former admin to them. They say I have to go back to the former HSA admin.
I contacted the former admin and inquired about transferring (normal transfer) the $177 back to them so that I could make a “distribution of excess contribution.” At first, I was told that it was unnecessary, as the account was now closed and would already be considered a withdrawal (but it was rolled over, a trustee-to-trustee transfer). Then, I was told that I could transfer the $177 back to them and then submit a “distribution of excess contribution form,” like I hoped.
However, I now realize that it would not be transferred with the relevant tax year info, and would also be placed in a new account. So, this would not result in the proper tax forms to satisfy the IRS (this last sentence is imprecise, as I do not fully understand which tax forms [5498-SA, 1099-SA, etc.] are necessary to satisfy the IRS that an excess contribution has been rectified).
Can anything be done before the tax deadline?
If not, do I just make sure that I under-fund my 2023 HSA by more than $177 under the limit, or do I need a documentation trail demonstrating that I specifically addressed this excess contribution?
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"Then, I was told that I could transfer the $177 back to them and then submit a “distribution of excess contribution form,” like I hoped. "
I think you should declare victory here, and do it this way. Yes, it's not the same account (but at least it's the same HSA custodian), but what is important here is that your tried to correct the situation as best as you could despite HSA custodians being notoriously reluctant to make any change out of the ordinary.
"do I just make sure that I under-fund my 2023 HSA by more than $177 under the limit," - Yes, this is the second thing to do, showing that your excess was properly discharged in the subsequent year.
Just document everything you did and why and stick it in your tax files in case anyone ever asks.
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