HSA eligibility when a spouse has an FSA

Executive overview

Employees enrolled in an HDHP can open an HSA — but only if they avoid disqualifying coverage. A traditional FSA counts as disqualifying coverage, even if held by a spouse.

Two FSA types are exceptions: limited-purpose FSAs (dental/vision only) and post-deductible FSAs.

If a spouse holds a traditional FSA, the employee cannot contribute to an HSA.

HSA eligibility requirements

• Must be enrolled in a high-deductible health plan (HDHP)
• Cannot be enrolled in Medicare or supplemental health insurance
• Cannot be claimed as a dependent on another's tax return
• Cannot be covered by any disqualifying health plan, including a traditional FSA

HDHP thresholds (2022)

• Minimum deductible: $1,400 individual / $2,800 family
• Out-of-pocket maximum: $7,050 individual / $14,100 family

FSA and HSA compatibility

• A traditional (general-purpose) FSA disqualifies an employee from contributing to an HSA
• This applies even if the FSA is held by a spouse, not the employee directly
• Both plans reimburse pre-deductible expenses — they cannot coexist

FSA types that allow HSA eligibility

• Limited-purpose FSA: covers dental and vision expenses only
• Post-deductible FSA: covers qualifying medical expenses only after the deductible is met
• Either type, even when held by a spouse, preserves the employee's HSA eligibility