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Can an individual participate in both a flexible spending account (FSA) and an HSA -OR- a health reimbursement arrangement (HRA) and an HSA?

IRS Revenue Ruling 2004-45 provides that an individual may participate in both an HSA and an FSA or HRA when the plan designs for the FSA and HRA are as follows:

Limited Purpose Health FSA or HRA

  • The FSA and HRA are limited to reimburse only vision, dental or preventive expenses. In addition, the limited purpose HRA may also reimburse specified-disease insurance, indemnity insurance and long-term care insurance.
  • Post-deductible Health FSA or HRA
  • The FSA and HRA are limited to reimburse expenses only after the minimum required HDHP deductible has been satisfied. Under this arrangement, the Post-deductible Health FSA and HRA are not required to have the same deductible as the HSA. The deductible need only be the minimum required HDHP deductible. For example, an individual who has single HDHP coverage with a $1,500 deductible may set up an FSA with a $1,000 deductible as this is the minimum required in 2004 under the regulations.
  • Retiree HRA
  • Reimbursement from the HRA begins after an employee retires from employment. Contributions are made to the HRA during the employee's active employment.

Last update on May, 16 2013 by Administrator.

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