HSA and Medicare Part D

[JDuns]

Has anyone else become concerned about the interaction between Medicare Part D and HSA rules?

Beginning in 2006, a HDHP may not cover prescriptions before satisfying the deductible (unless the IRS backs off of their vehement declarations to date that the transition rule will not be extended).

A prescription drug benefit that is subject to a HSA qualifying deductible will not be "creditable coverage" for purposes of Medicare Part D. If a medicare eligible individual who does not have creditable coverage does not enroll in Part D when first eligible, they will be subject to higher premiums as a delayed enrollee when they finally do enroll.

However, if they enroll when first eligible, they will have non-qualifying coverage that will make them ineligible to contribute to an HSA.

Does anyone see a way out of this result (unless CMS or the IRS does something)?

[jsb]

We made the same connection, but fortunately don't yet have a HDHP with a HSA to worry about yet. It seems clear that (so far) Part D and HSAs are not compatible. We're hoping the feds will resolve the conundrum before we move into HSA land.