I won’t need the answer to this until August, our benefits open season at work, but reading the IRS publication is making my head hurt.
So my employer offers an HMO, a PPO, or a high-deductible plan (for a lower premium). I chose the high-deductible plan this year, on the theory that my only predictable non-preventive health care expense is orthotics, which are specifically excluded from coverage on all the plans available to me. I figured this way, I could open an HSA, and throw money in there for vision, dental, orthotics, etc. But I am apparently getting to the point in my life where most years, something or another that requires non-preventive care is going to happen, and anytime anything at all happens, it seems to cost a minimum of $1,000 (which is the PPO annual deductible - I refuse to deal with HMOs because of really shitty prior experiences). So I’m thinking of switching back to the PPO once I get the chance.
This year, the annual HDHP deductible is $2,500, and the PPO deductible is $3,500, but if you pick the PPO, my employer is self-insured for expenses between $1,000 and $3,500 (you file claims and get reimbursed). So can I still have an HSA if I go with the PPO, or not? The relevant IRS publication says:
"Qualifying for an HSA
To be an eligible individual and qualify for an HSA, you must meet the following requirements. You must be covered under a high deductible health plan (HDHP), described later, on the first day of the month. You have no other health coverage except what is permitted under Other health coverage, later."
But Other Health Coverage is defined as:
"You…generally cannot have any other health coverage that is not an HDHP. …
Other employee health plans.
An employee covered
by an HDHP and a health FSA or an HRA that pays or reimburses qualified medical expenses generally cannot make contributions to an HSA. Health FSAs and
HRAs are discussed later. However, an employee can make contributions to an
HSA while covered under an HDHP and one or more of the following arrangements.
Limited-purpose health FSA or HRA. These arrangements can pay or reimburse the items listed earlier under Other health coverage except long-term care.
Also, these arrangements can pay or reimburse preventive
care expenses because they can be paid without
having to satisfy the deductible.
…
Post-deductible health FSA or HRA. These arrangements do not pay or reimburse any medical expenses incurred before the minimum annual deductible amount is met. The deductible for these arrangements does not have to be the same as the deductible for the HDHP, but benefits may not be provided before the minimum annual deductible amount is met."
Which deductible are they talking about??? Would I be OK, because the HDHP deductible is actually $3500, which is above the limit? Or not, because the HRA deductible is $1,000? Seriously, man, I think the IRS makes this shit confusing on purpose.