HSA eligibility for past years

[a908234]

For a previous tax year, I had primary and secondary insurance coverage.  The deductibles for both plans were in line with the HDHP limits for the year, so I took that as meaning I was eligible for an HSA.

A while after filing for that year, I found out that the secondary insurance had also included an integrated HRA.  Normally, this HRA would have disqualified me from HSA contributions.  However, I wasn't aware of the HRA at the time and didn't disburse from the HRA that year.

My question is, am I considered "covered" by something I didn't know existed?  Does the discovery of this HRA impact my HSA contribution?

[BillM223]

There are four types of HRAs that do not affect your HDHP coverage. From Pub 969:

However, an employee can make contributions to an HSA while covered under an HDHP and one or more of the following arrangements. 

• Limited-purpose health FSA or HRA. These arrangements can pay or reimburse the items listed earlier under Other health coverage except long-term care. Also, these arrangements can pay or reimburse preventive care expenses because they can be paid without having to satisfy the deductible. 

• Suspended HRA. Before the beginning of an HRA coverage period, you can elect to suspend the HRA. The HRA doesn’t pay or reimburse, at any time, the medical expenses incurred during the suspension period except preventive care and items listed under Other health coverage, earlier. When the suspension period ends, you are no longer eligible to make contributions to an HSA. 

• Post-deductible health FSA or HRA. These arrangements don’t pay or reimburse any medical expenses incurred before the minimum annual deductible amount is met. The deductible for these arrangements doesn’t have to be the same as the deductible for the HDHP, but benefits may not be provided before the minimum annual deductible amount is met. 

• Retirement HRA. This arrangement pays or reimburses only those medical expenses incurred after retirement. After retirement, you are no longer eligible to make contributions to an HSA.

So look into what kind of HRA you had, and your initial question may not matter.

[a908234]

Bill, I've confirmed with the HRA provider that the HRA in question was not one of the four types of HRAs you mentioned, so my coverage would have been affected.

[BillM223]

Well, it was worth the look.

"My question is, am I considered "covered" by something I didn't know existed?"

I am sure the IRS would say "yes". The HRA would appear to negate your HDHP coverage, which means that any HSA contributions made during the years you had HRA coverage would be in "excess".

I don't know which years are involved (hopefully just one), but you should start looking into amending that year (or years), because if you get into an audit and the IRS discovers this, they may hit you at the least with interest from that time.