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FAFSA Treatment of Employer-Sponsored HSA vs. Individual HSA

brantlybrantly 4277 replies77 threads Senior Member
Does anyone know the rationale behind this:

Tax-deductible contributions to an individual (not employer-sponsored) HSA must be reported on FAFSA and are added back into income for the purpose of determining financial aid—however, contributions to an employer-sponsored HSA that that are deducted from each paycheck do not even need to be reported on FAFSA and therefore are not added back into income for the purpose of calculating financial aid.

Why the inconsistency?

I cannot, for the life of me, imagine a justification for differentiating between employer-sponsored HSAs and non-employer-sponsored HSAs. It's not a loophole for the self-employed. It's an even playing field.

What am I missing?
14 replies
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Replies to: FAFSA Treatment of Employer-Sponsored HSA vs. Individual HSA

  • BelknapPointBelknapPoint 4953 replies19 threads Senior Member
    It's not just differentiating between employer-sponsored HSAs and non-employer-sponsored HSAs, it's differentiating between employer-sponsored HSA plan contributions made through payroll deductions and employer-sponsored HSA plan contributions made after tax that are reported as an above-the-line deduction on federal tax returns. You're right; it makes no sense.
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  • cptofthehousecptofthehouse 30394 replies59 threads Senior Member
    It’s where the lines are drawn. It’s not fair that contributions made by an employer to qualified plans are not added into income , but your own contributions are. Not fair at all. Here are a lot of things that are not fair in this process as well as with most processes.
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  • BelknapPointBelknapPoint 4953 replies19 threads Senior Member
    edited June 25
    It’s where the lines are drawn. It’s not fair that contributions made by an employer to qualified plans are not added into income , but your own contributions are. Not fair at all. Here are a lot of things that are not fair in this process as well as with most processes.

    You're missing the point. It's not about employer contributions to an HSA vs. employee contributions to that same HSA. Employee HSA contributions made through a cafeteria plan (payroll deductions) are not considered, while after tax employee contributions made to the same HSA account and taken as a tax deduction are considered by FAFSA. The federal tax implications are exactly the same either way and the contributed money can be used exactly the same way in either situation. It makes absolutely no sense for FAFSA to make a distinction here for federal student aid purposes.
    edited June 25
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  • thumper1thumper1 78287 replies3528 threads Senior Member
    I think it might have to do with choice.

    You don’t have a choice about HSA contributions contributed by your employer in most cases. You have a choice about HSA contributions you choose to make.

    I’m guessing, but this is what happens with some publicly funded retirement plans like teachers retirement. These amounts are not added back in as income because the teacher has no choice about the contribution amount. It is mandated by the state.
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  • cptofthehousecptofthehouse 30394 replies59 threads Senior Member
    It’s where the lines are drawn. It’s not fair that contributions made by an employer to qualified plans are not added into income , but your own contributions are. Not fair at all. Here are a lot of things that are not fair in this process as well as with most processes.

    You're missing the point. It's not about employer contributions to an HSA vs. employee contributions to that same HSA. Employee HSA contributions made through a cafeteria plan (payroll deductions) are not considered, while after tax employee contributions made to the same HSA account and taken as a tax deduction are considered by FAFSA. The federal tax implications are exactly the same either way and the contributed money can be used exactly the same way in either situation. It makes absolutely no sense for FAFSA to make a distinction here for federal student aid purposes.

    No, I’m not missing the point. I was giving a whole other example that is not “fair”. It’s just where the lines are drawn and do not always make sense.

    We have this very situation with HSAs ourselves as well as with qualified plans. There are a number of things not treated equitably for tax and FAFSA purposes.
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  • BelknapPointBelknapPoint 4953 replies19 threads Senior Member
    I think it might have to do with choice.

    You don’t have a choice about HSA contributions contributed by your employer in most cases. You have a choice about HSA contributions you choose to make.

    This isn't about employer contributions; it's about FAFSA making a distinction between two different ways for an employee to make a contribution to an HSA that in every other respect makes no difference. The lesson here is that for those who want to contribute to an employer-sponsored HSA and are expecting to use federal student aid, make all of your employee contributions through pre-tax payroll deductions.
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  • BelknapPointBelknapPoint 4953 replies19 threads Senior Member
    No, I’m not missing the point. I was giving a whole other example that is not “fair”. It’s just where the lines are drawn and do not always make sense.

    Well then, if you're comparing FAFSA treatment of employer and employee contributions to a qualified retirement plan (401(k), 403(b), etc.) with the FAFSA treatment of employer and employee contributions to an HSA, you're comparing apples to oranges.
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  • brantlybrantly 4277 replies77 threads Senior Member
    Thank you, @BelknapPoint . You see it the same way I do.

    I understand, @cptofthehouse , that some things are not considered "fair" by some people and that lines have to be drawn—but that characterization applies to drawn lines that people don't like but that are applied consistently. One that I can think of is that people who invest in houses to rent out and plan to sell the houses to fund their retirement do not like that their chosen retirement investment vehicle negatively affects their financial aid determination.

    But the issue I raise is wholly different. FAFSA is plain wrong in its treatment of HSAs. Either an HSA is income or it's not. The rule cannot be applied differently based on the method through which HSA contributions are deducted from income to create AGI. Self-employed people do not get paychecks from which HSA contributions can be deducted, so we have no choice but to take the income adjustment on our 1040.

    It's also a matter of age discrimination. Many older workers (50+) who lost jobs in 2008 or 2020 due economic downturns never were able to be rehired and therefore had to make a living through sole proprietorships. Independent contractors are disproportionately represented among older workers.

    @thumper1 Choice has nothing to do with it. Corporate employees who have HSAs CHOOSE whether and how much to contribute. It is deducted from their paychecks on a pretax basis.
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  • cptofthehousecptofthehouse 30394 replies59 threads Senior Member
    Sigh... But ..them’s the rules. I agree it’s not fair, makes no sense , not consistent. There are other such things as well. FAFSA has drawn those lines.
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  • twoinanddonetwoinanddone 24804 replies20 threads Senior Member

    I think it is a situation where FAFSA formula didn't keep up with the tax code . HSAs were a vehicle where the employee got to park some pre-tax income. There were limitation and I'm not sure employers contributed (mine didn't). It was also 'use it or lose it' for that 12-15 months, so there were no huge contributions ($5000 limit?) and no carry over. HSAs are now more of a savings vehicle where you can park some pretax income and the employer can also contribute funds to the HSA that are not considered income. It's more like a 401k with the employee's pretax contributions are added back to the income but the employer's contribution doesn't count in the FAFSA formula.

    Lots of things in the tax code aren't fair, and FAFSA is pretty good at carry those unfair policies over. Try being a single parent and getting half the allowances but still getting to pay the full tuition.
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  • BelknapPointBelknapPoint 4953 replies19 threads Senior Member
    I think it is a situation where FAFSA formula didn't keep up with the tax code . HSAs were a vehicle where the employee got to park some pre-tax income. There were limitation and I'm not sure employers contributed (mine didn't). It was also 'use it or lose it' for that 12-15 months, so there were no huge contributions ($5000 limit?) and no carry over. HSAs are now more of a savings vehicle where you can park some pretax income and the employer can also contribute funds to the HSA that are not considered income. It's more like a 401k with the employee's pretax contributions are added back to the income but the employer's contribution doesn't count in the FAFSA formula.

    It sounds like you may be conflating HSAs with FSAs, which both still exist but have very different rules. FSAs (Flexible Spending Accounts) have many of the attributes you describe above, most importantly, the "use it or lose it" limitation.
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  • brantlybrantly 4277 replies77 threads Senior Member
    It's more like a 401k with the employee's pretax contributions are added back to the income [ . . . ]

    This is NOT the case with HSAs. If you have an employer-sponsored HSA, the EMPLOYEE'S pretax contributions are NOT added back into income for FAFSA. That's my point. Employee contributions are not treated as income on FAFSA.

    However, tax-deductible HSA contributions ARE treated as untaxed income ONLY for self-employed workers. This has nothing to do with evolution of the HSA rules. It is highly (albeit unintentionally) discriminatory against older workers and female workers, who are way disproportionately represented among self-employed workers with individual HSAs.

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  • BelknapPointBelknapPoint 4953 replies19 threads Senior Member
    This is NOT the case with HSAs. If you have an employer-sponsored HSA, the EMPLOYEE'S pretax contributions are NOT added back into income for FAFSA. That's my point. Employee contributions are not treated as income on FAFSA.

    However, tax-deductible HSA contributions ARE treated as untaxed income ONLY for self-employed workers.

    Just to be clear, an employee with an employer-sponsored HSA can make either kind of employee HSA contribution: through payroll deduction with the employer, and also after-tax contributions directly from the employee that can then be taken as an above-the-line tax deduction. The direct employee contributions would suffer the same FAFSA treatment as similar HSA contributions from self-employed workers. Hence my remark above that for those who want to contribute to an employer-sponsored HSA and are expecting to use federal student aid, they should, as much as possible, make their employee contributions through pre-tax payroll deductions.
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  • brantlybrantly 4277 replies77 threads Senior Member
    edited June 25
    This is NOT the case with HSAs. If you have an employer-sponsored HSA, the EMPLOYEE'S pretax contributions are NOT added back into income for FAFSA. That's my point. Employee contributions are not treated as income on FAFSA.

    However, tax-deductible HSA contributions ARE treated as untaxed income ONLY for self-employed workers.

    Just to be clear, an employee with an employer-sponsored HSA can make either kind of employee HSA contribution: through payroll deduction with the employer, and also after-tax contributions directly from the employee that can then be taken as an above-the-line tax deduction. The direct employee contributions would suffer the same FAFSA treatment as similar HSA contributions from self-employed workers. Hence my remark above that for those who want to contribute to an employer-sponsored HSA and are expecting to use federal student aid, they should, as much as possible, make their employee contributions through pre-tax payroll deductions.

    Correct. If the contribution is not entered on a W-2 in Box 12 as Code W, it is added back into income.
    edited June 25
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