lawyerphoenix

Thank you both for your responses, I am wondering if either of you might be able to provide an answer to a follow up question: Assuming the providers are unable to collect the outstanding money from the participants, my understanding was then that only the affected participants would become HSA ineligible. However, the TPA has suggested that all participants in the HDHP, including those unaffected by the error, will become HSA ineligible since the HDHP is not longer a high deductible plan (because the HDHP made payments before the deductible was met for the select group of affected participants.) Put simply, the TPA believes that the HDHP early payments disqualifies all participants from HSA eligibility, not just the ones who had been paid before meeting their deductible. Is this approach consistent with anything either of you two have read? Thank you!

I represent a company that has an HDHP and HSA for employees. Due to a TPA error, several HDHP and HSA participants who had not yet reached their HDHP deductible were designated as though they had. Because of this designation, said participants began receiving reimbursements from the HDHP. Obviously, this would make said participants ineligible for an HSA since they are being covered by another medical plan before reaching their deductible. Is there a way for the affected participants to pay back the reimbursement monies paid by the HDHP so they could once again become HSA eligible? To further clarify, this has all happened within the 2017 calendar year.