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I started a HDHP medical plan and HSA account on 1/1/2019. We then had our first child on 1/8/2019. The OB/GYN office took a prepayment for the delivery services before 1/1/2019. So the question is: can I claim the part of the bill that I prepaid as an HSA distribution since the service date was after the creation of the HSA even though the payment date was before creation of the HSA?

Ben Miller
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Steve J.
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2 Answers2

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You can take a distribution from an HSA whenever you decide - as the previous answer said "it is the responsibility of the beneficiary to follow the rules". BUT if a qualified medical expense occurs before the HSA was established, then any distribution is taxable as income. Further, unless you were 65 or older, disabled or deceased at the time of the distribution there could be an additional penalty to the IRS of 20% of the distribution. However, if you get an explanation of benefits that shows all your charges occurred after the HSA was established, I think that would satisfy an audit by the IRS.

Derek McQuarrie
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  1. Simple approach: You just file a claim. It may or may not matter when you made the payment as long as the covered service was during your coverage period. The worst they can do is deny it.
  2. More complicated approach: Contact your insurer to see if they would allow this- you ask the OB/GYN for a refund of the prepayment, then immediately pay the OB/GYN the amount in full. That way both the service and payment are in your covered period.
Craig Srsen
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