GBS Health Benefits Compliance
HSA Eligibility Reference Guide
A Health Savings Account (HSA) is a tax-advantaged savings vehicle that allows individuals enrolled in a qualified High-Deductible Health Plan (HDHP) to set aside funds for eligible healthcare expenses. HSAs are intended to promote consumer engagement in healthcare decision-making and help participants manage both current and future medical costs.
Funds contributed to an HSA can be used to pay for qualified medical, dental, and vision expenses as defined by the IRS, or may be accumulated and invested for future healthcare needs, including those in retirement.
To be eligible to establish and contribute to an HSA, an individual must meet the following conditions:
- Be covered under a qualified High-Deductible Health Plan (HDHP) that meets IRS deductible and out-of-pocket maximum thresholds
- Have no other disqualifying health coverage, such as a traditional Health FSA or standard HRA.
- Not be enrolled in Medicare (Part A, B, C, or D).
- Not be claimed as a dependent on another individual’s tax return.
Employers may contribute to employees’ HSAs, allow pre-tax payroll deductions, and provide education about qualified expenses and compliance requirements. However, the account itself is owned by the individual, not the employer, and remains with the participant even if they change jobs or retire.
HSA Eligibility Matrix
This guide outlines what types of coverage, programs, and benefits individuals can be enrolled/ participating in while contributing to a Health Savings Account (HSA) under a High-Deductible Health Plan (HDHP).
Special Notes & Nuances
An individual can always spend from an HSA even if they become ineligible to contribute (e.g., after joining Medicare). In other words, they may spend existing contributions but may not contribute tax free to the HSA.
Preventive care is always allowed, even when the deductible has not yet been met.
Individuals may use telehealth before the deductible is met. This was a temporary COVID rule but in July 2025 Congress pass a law that included permanent relief allowing HDHPs to provide first-dollar telehealth and other remote care services without losing the ability to contribute to their HSA
FSAs & HRAs must be limited-purpose or post-deductible to remain HSA-compatible.
Spousal coverage is a very common but unintended trigger for losing individual HSA eligibility, e.g. if a spouse’s plan or health FSA covers an individual who is on an HSA/HDHP, it can disqualify the HSA contributions.
November 2025
This document is not intended to be exhaustive, nor should any information be construed as tax or legal advice.
