Anyone with a health savings account files this, and eligibility to contribute is tested month by month rather than once for the year.
That monthly test is where positions go wrong. A change of health cover part way through the year, or coverage that starts late, changes what could be contributed and is rarely noticed until the return is prepared.
This covers who has to file, what makes somebody eligible, how contributions and distributions are reported, how employer contributions count, and what happens when more went in than the rules allowed.
What Is Form 8889?
IRS Form 8889, Health Savings Accounts (HSAs), is filed with your Form 1040 if you contributed to an HSA, made distributions from an HSA, or need to report an employer's HSA contributions during the year. It determines your deduction for HSA contributions and calculates any taxes or penalties on non-qualified distributions.
Eligibility is tested month by month and depends on the cover in place, so a change of plan part way through the year is exactly when the position becomes complicated. Keep evidence of eligibility for each month you contributed, alongside receipts for what came out.
Ankit Sarawagi, CPA, CA, MBA · LinkedInWho Must File Form 8889?
- Anyone who contributed to an HSA during the year (including employer contributions made through a cafeteria plan).
- Anyone who took a distribution from an HSA.
- Anyone who had excess HSA contributions.
- Anyone who needs to report their HSA account balance or activity.

HSA Eligibility Requirement
To contribute to an HSA, you must be covered by a High Deductible Health Plan (HDHP) and not enrolled in Medicare, not be claimed as a dependent on someone else's return, and not have other disqualifying health coverage.
Part I: HSA Contributions
Part I calculates your HSA contribution and determines your deduction:
| Item | 2025 Amounts |
|---|---|
| Individual (self-only) coverage limit | $4,300 |
| Family coverage limit | $8,550 |
| Catch-up contribution (age 55+) | +$1,000 additional |
- Include contributions you made directly AND contributions your employer made on your behalf.
- Contributions through payroll are pre-tax; direct contributions are above-the-line deductions.
- The deduction is capped at the annual limit regardless of how contributions were made.
Part II: HSA Distributions
Part II reports what you withdrew from your HSA and determines tax consequences:
- Qualified medical expenses: distributions are tax-free and penalty-free.
- Non-qualified distributions: taxable as ordinary income PLUS a 20% additional tax (penalty).
- Exception to 20% penalty: distributions after age 65, or due to death or disability (still taxable as ordinary income but no 20% penalty).
What Are Qualified Medical Expenses?
Qualified medical expenses include amounts paid for diagnosis, cure, mitigation, treatment, or prevention of disease, for yourself, your spouse, or dependents. Common examples:
- Doctor visits, hospital costs, lab fees.
- Prescription drugs and insulin.
- Dental and vision care.
- Certain over-the-counter medications (expanded permanently by CARES Act).
- Long-term care insurance premiums (subject to limits).
- COBRA premiums while unemployed.
- Medicare premiums (after age 65).
Part III: Income and Additional Tax on Excess Contributions
If you contributed more than the annual limit, the excess is:
- Included in your gross income.
- Subject to a 6% excise tax for each year the excess remains in the HSA.
- You can withdraw the excess (plus attributable earnings) by the tax filing deadline (including extensions) to avoid the 6% tax.
Last-Month Rule
If you are HSA-eligible on December 1, you can contribute the full annual limit regardless of how many months you were covered during the year. However, you must remain HDHP-eligible for the entire following calendar year (testing period). If you don't, you must include the excess contribution in income plus pay a 10% penalty.
How to Complete Form 8889
- Check Part I, Line 1, Individual or Family coverage.
- Enter all contributions (yours + employer's) on the appropriate lines.
- Calculate your deduction (excess over employer contributions is deductible).
- Enter distributions in Part II, identify qualified vs non-qualified.
- Compute any taxes or penalties in Part III if applicable.
- Transfer deduction to Schedule 1 (above-the-line deduction, Form 1040).
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Frequently Asked Questions
Does my employer's HSA contribution count toward the annual limit?
Yes. Your employer's contributions count toward the annual maximum. The total of your contributions plus employer contributions cannot exceed the annual limit.
Can I use HSA funds for a family member's medical expenses?
Yes, if the family member is your spouse or a dependent on your tax return.
What happens to my HSA after age 65?
After age 65, you can still use HSA funds for qualified medical expenses tax-free. For non-medical withdrawals, the 20% penalty goes away, you pay only ordinary income tax, just like a traditional IRA withdrawal.
Can I contribute to both an HSA and a Flexible Spending Account (FSA)?
Generally no. Contributing to a general-purpose Health FSA disqualifies you from HSA contributions. A Limited-Purpose FSA (dental/vision only) is compatible with an HSA.
What should be kept alongside the account each year?
Evidence of eligibility for each month you contributed, and receipts for every distribution. Eligibility is tested month by month and depends on the coverage in place, so a change of plan part way through the year is exactly when the position becomes complicated. Receipts matter because a distribution is only free of tax if it was used for a qualifying purpose, and that is proved by you rather than reported by the administrator.
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