You cannot open a new HSA without being enrolled in a high-deductible health plan (HDHP), but you may be able to keep one you already have if you lose coverage.
The IRS ties HSA may be able to access directly to HDHP enrollment. You must be covered by an HDHP on the first day of the month you want to contribute to an HSA. If you don't have an HDHP, you cannot open an HSA account, and most financial institutions will not let you fund one.
The exception is narrower than it sounds: if you already own an HSA and you lose your HDHP coverage, you can keep the account and the money in it. You straightforward cannot add new contributions once you're no longer covered by an HDHP. The funds you've already saved remain yours to spend on may have access to medical expenses at any time, with no time limit.
Key Takeaways
- Opening an HSA requires current enrollment in a high-deductible health plan; without one, you cannot establish a new account.
- If you already own an HSA and lose your HDHP coverage, you keep the account and all the money in it, but cannot make new contributions.
- Once you're no longer may be able to access to contribute, you can still withdraw funds for may have access to medical expenses without penalty, though withdrawals for non-medical expenses are taxed as income.
- If you regain HDHP coverage later, you can resume contributions to an existing HSA or open a new one.
What counts as a high-deductible health plan
An HDHP is a specific type of health insurance with a deductible that meets IRS minimums. For 2024, the minimum deductible is $1,600 for self-only coverage and $3,200 for family coverage. The plan must also have an out-of-pocket maximum (the most you pay before insurance covers 100 percent) of no more than $4,050 for self-only or $8,050 for family.
Not all high-deductible plans may have access to. Your plan must be labeled as an HDHP or meet the IRS definition. If you're unsure whether your current plan qualifies, your employer's benefits office or your insurance company can confirm it. Some plans have high deductibles but don't meet the other IRS requirements, which means they don't unlock HSA may be able to access.
What happens if you lose coverage mid-year
If you lose your HDHP coverage during the year—through job loss, divorce, or a change in your employer's plan offerings—you stop being able to contribute to your HSA as of the month you lose coverage. However, you do not have to close the account or withdraw the money.
Money already in the account stays there indefinitely. You can withdraw it for may have access to medical expenses (doctor visits, prescriptions, dental work, vision care, and many other health-related costs) without penalty or tax, even years later. If you withdraw funds for non-medical reasons, you'll owe income tax on the withdrawal amount, plus a 20 percent penalty—but only on the amount you withdraw for non-medical use, not on the entire balance.
Regaining may be able to access and restarting contributions
If you enroll in a new HDHP later—whether through a new job, the individual market, or Medicare Advantage—you can resume contributing to an existing HSA or open a new one. There's no waiting period or penalty for the gap in contributions. Your previous balance remains untouched and available.
The timing matters slightly: you can only contribute for months in which you're covered by an HDHP. If you enroll in an HDHP on March 15, you cannot contribute for January or February, but you can contribute for March onward. Some people use this to their advantage by timing enrollment to maximize contribution room in a given year.
Why employers and banks enforce the HDHP requirement
The HDHP requirement exists because HSAs are tax-advantaged accounts. Contributions reduce your taxable income, growth is tax-free, and withdrawals for medical expenses are tax-free. The IRS limits this benefit to people in high-deductible plans, on the theory that these plans encourage cost-conscious health spending.
Banks and HSA custodians verify HDHP enrollment because they face penalties if they allow ineligible people to contribute. Most will ask for proof of coverage when you open the account and may ask again if you make contributions after a gap. If you contribute while ineligible, the IRS can assess taxes and penalties on those contributions, so custodians take this seriously.
Alternatives if you don't have an HDHP
If you have a standard health plan (PPO, HMO, or POS) with a lower deductible, you cannot use an HSA. Your options for tax-advantaged savings depend on your income and employment status.
If you're employed, you may have access to a Flexible Spending Account (FSA), which lets you set aside pre-tax money for medical and dependent care expenses. FSAs have lower contribution limits than HSAs and operate on a use-it-or-lose-it basis (though some plans allow a small carryover). If you're self-employed or have no employer plan, you cannot open an FSA.
If you're self-employed, you can deduct health insurance premiums directly on your tax return as a business expense, which provides some tax benefit but not the same advantage as an HSA. You might also consider switching to an HDHP if your health needs allow it—many individual market plans now offer HDHP options at competitive rates.
Frequently Asked Questions
Can I open an HSA if I'm on Medicare?
No, not on Original Medicare. Once you enroll in Medicare Part A or B, you're no longer may be able to access to contribute to an HSA. However, some Medicare Advantage plans (Part C) are structured as HDHPs and do allow contributions. Check with the plan directly before enrolling. If you already own an HSA, you keep the account and can withdraw funds for any medical expense without penalty.
What if my spouse has an HDHP but I don't?
You cannot open a joint HSA. Each person must have their own HSA and their own HDHP coverage. If you're on a family plan together, you both need to be covered by the same HDHP to each contribute. If only one spouse is covered, only that spouse can contribute.
Can I withdraw HSA money for non-medical expenses without penalty if I'm no longer covered?
You can withdraw the money, but you'll owe income tax on it plus a 20 percent penalty. The penalty applies whether you're currently covered by an HDHP or not. The only way to avoid the penalty is to use the money for may have access to medical expenses. Once you turn 65, the penalty goes away (though income tax still applies to non-medical withdrawals).
What if my employer drops HDHP coverage?
You lose may be able to access to contribute once the plan ends. If your employer offers a different plan that qualifies as an HDHP, you can contribute to your HSA under that plan. If they don't, you keep your existing HSA balance but cannot add to it. You can search the individual market for an HDHP if you want to resume contributions.