What is my HSA establishment date?
• Generally, the Establishment Date of your HSA custodial account is the later of the effective date of your qualifying HDHP coverage or the date you provide evidence of intent to open the account (e.g., completion of some type of form or application requiring your signature that acknowledges your desire to open an HSA), notwithstanding the fact that deposits or a signature card have not been received, required regulatory and compliance activities have not been completed and the account is not yet operational. The “Establishment Date” of an HSA is important because you can only receive tax-free distributions from your HSA to pay or be reimbursed for qualified medical expenses incurred after the date the HSA is considered “established”. Because you are ultimately responsible for determining which expenses are reimbursable from your HSA, you should consult with your personal tax advisor to determine how IRS guidance on this issue should be applied to your specific situation.
