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What are all the documents you can use as proof of HSA eligible spending?

If you present proof/receipts that show you paid for qualified medical expenses out of pocket, are you allowed to reimburse yourself at any time in the future by withdrawing from your HSA tax and penalty free?

 

What are all of the options you can use as proof of payment for qualified medical expenses? If I've had my HSA for a few years, haven't taken anything out of it, and don't plan to for many years, can I go back to my health insurance provider website for those years and download a document showing what my overall out of pocket spending was? Or something that shows what "you may owe"?

 

Since it's been a few years I obviously don't have receipts for every medical expense I've had, but I can see the out of pocket amount I spent in those years. What specifically should I go download and save as proof for future reimbursement?

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7 Replies
JohnB5677
Employee Tax Expert

What are all the documents you can use as proof of HSA eligible spending?

Yes, you can pay for medical costs from your HSA at any time, even years later. 

  • You won't pay taxes or penalties. 
  • If you took an itemized deduction on your taxes, you can't get a reimbursement.
  • The HSA must be set up before any reimbursement will qualify for reimbursement.
  • Other than setting up the HSA there's no limit to how long you can wait for reimbursements.
  • Expenses must be for yourself, spouse, or dependents. 

To prove medical costs

  • Keep detailed records. 
    • Invoices, 
    • Receipts, and 
    • Explanation of Benefits (EOB) 
      • Notes that include 
        • The provider, 
        • Date, 
        • Type of service, and 
        • Patient. 

Keep these records with a copy of your taxes to prove they were necessary, out-of-pocket expenses.

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What are all the documents you can use as proof of HSA eligible spending?

What if it was years ago and I don't necessarily have all that info? Is there something I can easily go back and download from my health insurance provider at that time that would suffice? Like something from my insurance provider that shows what my out of pocket spending was / how much toward my out of pocket max I spent?

 

Also if I rollover an HSA I opened in 2022 into an HSA that I opened in 2026, can I still reimburse myself for medical expenses from 2024? Is there a way to prove that my 2026 HSA contains an HSA from 2022 that was rolled into it?

BillM223
Employee Tax Expert

What are all the documents you can use as proof of HSA eligible spending?

One way to document these expenses is to get a debt card from your HSA custodian and use it for medical expenses. First this card won't allow you to pay for things that are not medical expenses (but many OTC products are OK), and second, this creates an electronic trail that you can follow.

 

Now that doesn't help retroactively. For older expenses, do as John says and make a list of items spent for, along with the date and other info. There is no prescribed formula for how to show this, so your job is to be able to make a plausible presentation to an IRS agent during an audit.

 

"Also if I rollover an HSA I opened in 2022 into an HSA that I opened in 2026, can I still reimburse myself for medical expenses from 2024? Is there a way to prove that my 2026 HSA contains an HSA from 2022 that was rolled into it?"

 

Yes. You will treat these two HSAs as one virtual HSA, so that as far as the current HSA is concerned, it was opened in 2022. Just keep the paperwork showing that you opened the original HSA in 2022 and that you did the rollover in 2026 or so.

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What are all the documents you can use as proof of HSA eligible spending?

Interesting, do you know if Fidelity HSAs have this debit card? And do these cards not just spend directly from your HSA rather than saving it for later reimbursement?

BillM223
Employee Tax Expert

What are all the documents you can use as proof of HSA eligible spending?

I do not know about Fidelity in particular, but my HSA provided a debit card so that is how I did 100% of my current expenses.

 

And, yes, suppose you were paying a co-pay at your doctor's or buying prescriptions or whatever - you could use the debit card rather than a check or credit card and having to reimburse yourself later.

 

Of course, you have to have the dollars in your HSA to use a debit card, so that is a motivation to contribute the max amount to your HSA each year.

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What are all the documents you can use as proof of HSA eligible spending?

Well my question is won't you be actually spending directly from your HSA if you do that and use that debit card? Because my whole point is to not spend from my HSA so I can leave the money it in as an investment.

BillM223
Employee Tax Expert

What are all the documents you can use as proof of HSA eligible spending?

Of course using your HSA debit card is spending directly from your HSA. The whole point of an HSA is to pay for qualified medical expenses with tax-advantaged dollars.

 

It is true that you can invest money in your HSA, and draw them out even after you retire, but you might have trouble finding an HSA custodian that gives you the breadth of investment opportunities that an IRA might provide.

 

Once you turn 65, the HSA becomes like an IRA in that you can withdraw money from the HSA then and be taxed like ordinary income just like an IRA - with the added bonus that if the money is withdrawn for purposes of paying for qualified medical expenses than these dollars are still tax-free.

 

It sounds like you want to maximize your HSA contributions in order to be able to cover your current medical expenses and still keep the investing going.

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