Apr '19: I've recently worked w/ my HSA trustee/custodian (my CU) to correctly code HSA reimbursements transactions in early 2018 for HSA Qualified Distributions in 2017. Same for 2019/2018. So we caught the 2018 1099-SA reporting for this past tax year.

However, I now have a Corrected 1099-SA for 2017 and need to fix my 2017 HSA form 8889. What parts of the 1040X do I need to fill out other than the top part & explanation, if there is no tax impact?

I've done much research and do not see any help for this.

Thanks for the feedback re. my question. "but for some reason you got them recoded to apply to 2017. What was the purpose of that?"

Based on discussions with the Compliance Analyst at my CU, the Trustee for the HSA acct, they need to keep their records straight re. refunds, credits & reimbursements to the account. That is, if the deposits I made in early 2018 were a refund, credit or reimbursement for a prior year qualified medical expense they need to connect those events or transactions.

According to their 1099-SA Gross Distribution reporting these fall under “HSA Mistaken Distributions” (pg 1 of Instructions for 1099-SA and 5498-SA).

“the account beneficiary may repay the mistaken distribution no later than April 15 following the first year the account beneficiary knew or should have known the distribution was a mistake.”

The Trustee/Custodian does not have to allow these, and I (the Beneficiary) was unaware of this category or that it even mattered to the Trustee. 2017 was the 1st year that this seemed to affect my reporting or rather that the Gross Distribution Amt on the 1099-SA did not agree with my Figures. I did call the Trustee last year (2018) while putting my 2017 taxes together to find out more but ended up answering my own question by deciding to not include the wrap-around transactions in 2018 and include them in 2018.

This all came to a head while filing my 2018 taxes this year. But after some discussions and figure exchanges with the Compliance Analyst at my CU we were able to come to an understanding for correcting the 2017 & 2018 1099-SA forms and how to properly code these types of deposits moving forward.

Side Note: The HSAs are not structured for modern-day Healthcare transactions.

I now need to go back and fix my 2017 8889 Form to properly reflect the correct amounts in 14a and 15 to match the corrected 1099-SA my CU sent them. 14a) Total distributions you received in 2017 from all HSAs 15) Qualified medical expenses paid using HSA distributions

So, my question is What parts of the 1040X (Amended Return) do I need to fill out other than the top part & explanation, if there is no tax impact? Because it seems like the lines on the 1040X are for changes in your overall tax. According to the about page for the 1040x: File Form 1040-X to do the following. • Correct Forms 1040, 1040-A, 1040-EZ, 1040-NR, or 1040-NR EZ. • Make certain elections after the prescribed deadline. • Change amounts previously adjusted by the IRS. • Make a claim for a carryback due to a loss or unused credit.

When you look at the instructions for the 1040x it has a section for which lines you should fill out, but nowhere in the instructions does it mention forms or cover HSA, 8889 changes. I hope this helps to explain what I am trying to understand re. the IRS tax code for HSA's.


Yes, in fact these were checks from Ins providers that I deposited directly into the HSA acct. So, they were a true reimbursement, as it should be in HealthCare today.

Not this out-of-pocket business from another acct. and reimbursement from my HSA. Sorry, my commentary on the outdated HSA rules.

So do you know how to accurately file an amendment for something like this? I’m thinking a revised 8889 and a 1040X with only a statement of explanation for the revised 8889 form.

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    I don't understand your question. In the first sentence, it seems that you said that you had HSA reimbursements (distributions from your HSA) in early 2018, but for some reason you got them recoded to apply to 2017. What was the purpose of that?
    – Ben Miller
    Commented Apr 22, 2019 at 2:15
  • I think I understand now. When you said “HSA reimbursement transactions,” you were not talking about a reimbursement of a qualified medical expense to you, but instead you were talking about a Mistaken Distribution repayment by you back to your HSA.
    – Ben Miller
    Commented Apr 23, 2019 at 15:25

1 Answer 1


I believe your assessment is correct:

I’m thinking a revised 8889 and a 1040X with only a statement of explanation for the revised 8889 form.

Even though there is no net tax changes, which logically would lead you to believe a 1040X is not necessary, without the properly filed 8889 form there actually is a tax liability. From the IRS' point of view, 2017 now has HSA distributions that you never reported on the 8889 form, and therefore the IRS will assume (since you didn't state otherwise) that those distributions were not eligible medical expenses. If you do nothing, it's likely that within the next 2 years you'll receive a CP-2000 notice stating you owe tax and penalties on the new 2017 HSA distributions. So, filing the 1040X with the 8889 form is your way of saying there actually should be no tax liability.

  • Thank you Joe for the verification. Sorry it took me a while to respond. Although I was able to merge my 2 user ID's. Thanks for pointing that out & I will try to add a nickname. J9
    – J9R
    Commented Apr 29, 2019 at 13:48

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