Employers implementing HSA-eligible consumer-directed health plans will almost certainly confront participant concerns about greater cost exposure from higher deductibles and other required cost-sharing features. There are a number of creative approaches employers and participants can take to manage financial risk while leveraging the tax-preferred features of an HSA (or a health reimbursement account). Participants can consider the following strategies:
Full contribution rule. An individual who is otherwise ineligible to make a full-year HSA contribution (because, for example, they enroll in the plan mid-year, or have a health FSA grace period balance from the prior year) can make a full-year contribution for the current year, if they (1) are HSA-eligible on December 1, and (2) remain HSA-eligible for the entirety of the following year. This helps participants who are subject to the full annual deductible but would otherwise be unable to fund an HSA to pay for qualifying expenses.
Provider payment plans. While not specific to CDHPs, it’s worth noting that providers – namely hospitals and physicians – generally permit patients to establish a payment schedule to retire their out-of-pocket expenses. This means a plan member might not have to pay their entire deductible or other out-of-pocket exposure with a single payment. Participants could work with their provider(s) to align payments with their pay periods, so they can fund their HSA on a pay period basis and simultaneously pay the provider with tax-free HSA distributions.
Permitted coverage / supplemental health insurance. Certain types of insurance that can be disregarded when determining whether an individual is eligible to contribute to an HSA, for example, critical illness insurance, certain types of accident insurance, and hospital indemnity policies. While these types of coverage are generally offered on a voluntary basis, it is possible for the employer to subsidize this coverage, although the coverage will then generally be being deemed subject to ERISA, invoking compliance-related considerations. Regardless, some employers may find it beneficial to subsidize these types of coverage. Lower-wage / risk-averse participants may value the additional coverage more highly than an employer HSA contribution.
The rise of the CDHP has brought real and perceived financial risk challenges to the forefront for both employers and participants. It’s important for employers to ease participants’ concerns and build their confidence with effective benefits communications about how they can get the most out of an HSA.
This post is part of our 2017 Planning Checklist series.