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High-deductible Health Plans (HDHP) and Health Savings Accounts
2010 Oct 12, 8:41am 1,564 views 2 comments
by justme follow (1)
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justme
2010 Oct 12, 10:09am
Here is what irs969 has to say about what is preventive care:
An HDHP may provide preventive care benefits without a deductible or
with a deductible below the minimum annual deductible. Preventive care
includes, but is not limited to, the following.
1. Periodic health evaluations, including tests and diagnostic
procedures ordered in connection with routine examinations, such as
annual physicals.
2. Routine prenatal and well-child care.
3. Child and adult immunizations.
4. Tobacco cessation programs.
5. Obesity weight-loss programs.
6. Screening services. This includes screening services for
the following:
a. Cancer.
b. Heart and vascular diseases.
c. Infectious diseases.
d. Mental health conditions.
e. Substance abuse.
f. Metabolic, nutritional, and endocrine conditions.
g. Musculoskeletal disorders.
h. Obstetric and gynecological conditions.
i. Pediatric conditions.
j. Vision and hearing disorders.
For more information on screening services, see Notice 2004-23, 2004-15
I.R.B. 725 available at www.irs. gov/irb/2004-15_IRB/ar10.html. The
following table shows the minimum annual deductible and maximum annual
deductible and other out-of-pocket expenses for HDHPs for
2009. Publication 969 (2009)
I submitted an application for Blue Shield of California plan Vital Shield Plus 2900 Generic Rx. This plan has a 2700 deductible and a maxOOP (out-of-pocket) of 4900 with a base premium of about $200-220/month for my age group.
Based on those numbers, and what Wikipedia and IRS says (references below), I'd say this plan qualifies me to start an HSA account and contribute up to 3050 per year pre-tax to the account.
But then I phoned BS to check on my application, and they said that only the so-called Shield Savings accounts qualify for HSA.
Are they wrong? AFAICT, the only requirements for an HSA are
R1: deductible > 1200 (single), 2400 (family)
R2: maxOOP < 5950 (single), 11900 (family)
R3: only "preventive care" must be free
That R2 is a "less than" is slightly surprising , perhaps it is just consumer protection, I dunno. But in any case I think the VSP2900PGRX (sounds like a sports car, does it not) qualifies. And in any case it is the IRS and not BS that gets to decide, is it not?
Am I missing something here? It could be that for a family there are 3+ family members then one would run afoul the 11900 number, but I don't and that should not disqualify the plan as a whole, only certain configurations or uses of it.
By the way, the BlueShield so-called Shield Savings series of plans are listed as qualified, but I do not like them because they have no free or low-cost office visits at all except preventive care (annual physical I assume that means). This must be related to R3. But when I read irs969 it has a fairly expansive view of what constitutes "preventive care", and then the question is who gets to decide and who is going to check? The IRS?
References:
http://en.wikipedia.org/wiki/Health_savings_account
http://en.wikipedia.org/wiki/High_Deductible_Health_Plan
http://www.irs.gov/pub/irs-pdf/p969.pdf
(I added R3 and related material as I discovered it).