Health Savings Plan Distributions & 1099-SA

If you have made a regular contribution to a Health Savings Account (HSA), an Archer MSA or a Medicare Advantage MSA Plan, for yourself or on behalf of another (as a trustee or custodian) and have distributions to report, you must file a 1099-SA. In fact, if you have more than one plan, a separate return must be filed for each plan type.

There are general instructions from the IRS for “Certain Information Returns” (https://www.irs.gov/pub/irs-pdf/i1099gi.pdf) posted on the IRS website. These instructions include who must file, when and where to file, electronic reporting, corrected and void returns as well as statements to recipients, TINs – Taxpayer IDs, backup withholding, penalties and other topics. Search separately for the 1099SA instructions and the Form 5498SA instructions.

The Form 5498-SA must be filed to report any rollovers, for instance a trustee-to-trustee transfer from an IRA to an HSA. It’s important to understand the specifics of a transfer under section 408(d)(9) which include contributions to the HSA subsequently closed by the custodian or trustee. A Form 5498-SA must be filed for each person for whom you maintained an HAS, Archer MSA or Medicare Advantage MSA – as a trustee or custodian.

Specifically, a Form 5498-SA must be filed with the IRS on or before May 31, 2023 for each person for whom you may have maintained an HSA, Archer MSA or Medicare Advantage MSA during 2022. For the HAS or MSAs, contributions made between January 1, 2023 and April 18, 2023 – it’s important to obtain the designation of the year for which the contributions were/are made.

In addition to these two forms, those who have Health Savings Accounts must file a Form 8889 and attach it to Form 1040, 1040-SR or 1040-NR even if you didn’t take a distribution from these accounts to pay for qualified medical expenses. This is even if the distribution is not taxable. The distribution must be included in your income. You will be warned to also complete a Form 8853 for reporting Archer MSA’s and Long-Term Care Insurance Contracts if required.