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Does the employer or the health plan need to verify that distributions from the Health Savings Account are for qualified services?

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No. The participant needs to make that determination and should maintain records of their medical expenses to verify the expenses are for qualified services and therefore excludable from their gross income. This self-substantiation guideline is used for MSAs and will apply to HSAs. The IRS may request receipts during a tax audit. Employers and plan administrator are not responsible or liable for misuse (i.e., use for non-qualified medical expenses of HSA dollars by plan participants.

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