Mr. HSA

Art, if you are willing to email me at roy@mrhsa.com, I would be happy to help you get some answers before you reach out to banking regulators or the CFPB. I am a consultant to the American Bankers Association HSA Council and may be able to help you get this resolved pro bono.

I agree. And with IRS "rounding" rules (to the nearest dollar), it would be $0.00 anyway.

I have became aware of recent bulletins from the insurance regulators in several states that appear to require health insurers to cover treatment (and testing) related to monkeypox without cost-sharing during the public health emergency (PHE) declared by the federal government for monkeypox. I am not aware that the federal PHE declaration for monkeypox requires insurers to cover testing and treatment for monkeypox, so this appears to be an action initiated by state regulators. Unfortunately, some of these bulletins provide no exception for HSA-qualified plans so I'm concerned that both bulletins are problematic for HSA account owners with state-regulated HDHPs. Has anyone else come across these situations? CA All Plan Letter 22-019 - Health Plan Coverage of Monkeypox Testing, Vaccinations, and Therapeutics.pdf NM Bulletin 2022-17 Monkeypox PHE.pdf

Nothing in the HSA statute requires an individual to be a U.S. citizen to establish and contribute to an HSA. However, non-citizens face two challenges when try to establish an HSA. First, and likely the biggest challenge to overcome, most non-citizens have health care coverage from their home country that would disqualify their HSA eligibility even though they are enrolled in a U.S.-based "HSA-qualified" high deductible health plan. Second, non-citizens may also have issues passing U.S. "Patriot Act" requirements such as the Customer Identification Program (CIP) and Know Your Client (KYC) when attempting to establish a financial account like an HSA.

Yes, there is a way. The TPA needs to re-process the claims to show the correct application of the deductible and patient responsibility via revised EOBs. The providers won't be happy since it means they will now have to collect the outstanding money from the patients. Patients won't be happy but should understand that they hadn't really met their deductibles yet.