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I have a bill from my doctor for 2 services, one was performed in January and the other was in March. I have had my HSA for several years and these are qualified medical expenses. Since I have a single bill for that is my receipt for services rendered, I plan to submit a reimbursement request for this bill, but I was wondering how do I handle that there are 2 different dates for "date expense incurred" ?

I am wondering what's the best way to account for this. My HSA provider only allows for a single date to be entered when submitted the request

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    Is the bill itemized showing how much is for which service?
    – littleadv
    Apr 2, 2023 at 2:41
  • Yes, the bill is itemized showing the cost of each service, one in Jan and one in March Apr 3, 2023 at 20:55

3 Answers 3

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As long as both dates are in the same year, it shouldn't make any difference. It's pretty common for a doctor's bill to include multiple dates of service, so it's funny that the HSA form doesn't allow for this. But I'd say the safest thing to do is to submit two different reimbursement requests, one for each date. Make two copies of the bill and highlight the charges relevant to each reimbursement request.

Or probably the really best thing to do is call the HSA custodian and ask them what you're supposed to do.

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  • Thank you for the suggestions, this makes sense and is helpful Apr 3, 2023 at 21:10
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The HSA form I used when I had an HSA allowed you to specify either a single date, or a range of dates, or to specify "multiple dates". In many cases even a simple thing could be spread over multiple days: lab work, an x-ray, dental work. The reimbursement claim form could also handle multiple medical expenses on a single form. I would include all the items from a single EOB onto a single claim form.

In my experience I also wanted to wait for the EOB (Explanation of Benefits) to be generated by the insurance company before making a claim. This was for two reasons: to show the final amount after the insurance company processed the claim, and to prove that I wasn't claiming funds that were also being paid for by the insurance company.

I also found the paperwork was simpler when the funds were being sent to the medical providers office, versus reimbursing me for expenses I had already paid. Some providers were happy with that arrangement, while others wanted me to use my medical expense debit card at the office or a regular credit card and then have to get a refund from the provider, and then put the funds back into the fund, or get a check from the fund.

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    Personally, my HSA provides me with a debit card, and I always pay my medical bills with the debit card. They then pay the provider directly and I have literally zero paperwork. That way I never have to apply for reimbursement and it saves a whole bunch of paperwork and nuisance. Not sure if that option is available to OP.
    – Jay
    Apr 2, 2023 at 18:27
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    @Jay: That's fine for out-of-pocket expenses such as copays, medications, etc., but if you're paying for something that your HDHP covers, then you want to process it through insurance so that it counts against your deductible (even though the money will ultimately come out of your HSA).
    – Kevin
    Apr 3, 2023 at 17:14
  • @kevin In my case, the doctor or pharmacy sends the bill to my insurance company, then they bill me for the difference, which I pay with the HSA debit card. In the case of my pharmacy, they can bill the insurance and know what the insurance will pay in a matter of seconds, so at the time I pick up the prescription they just tell me what the difference is and I hand them the HSA card to pay for it. For a doctor, they send it in and I get a bill a few weeks later, and then usually I pay it on their website, again with the HSA card.
    – Jay
    Apr 4, 2023 at 15:43
  • Maybe your insurance, HSA, or doctor doesn't work the same. I find this works very easily for me. Whether you could do the same, I don't know.
    – Jay
    Apr 4, 2023 at 15:46
  • @Jay: In my case, I believe my insurance puts a bill directly in my HSA's online user interface, and I can then pay it out of pocket or out of HSA as I see fit, no debit card required.
    – Kevin
    Apr 4, 2023 at 16:24
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Different HSA providers have different policies. The form that they have you use for reimbursement is of their own design; there is no regulatory requirement that they get any information from you at all before they issue a reimbursement.

Some HSA providers have you "prove" the medical expense by submitting information about the medical service and/or submitting receipts/invoices, but this is only to help you to know what is a qualified medical expense, to prevent you from making a costly mistake, and to assist you with records management. Other HSA providers (including mine) do not take any information from you at all when issuing a reimbursement; you simply request the reimbursement and you get it, and it is up to you to keep all of your own records and ensure that you are using the account correctly.

You won't find the answer to your question of how you should handle this situation on any IRS publication; the only one who can answer this is your HSA provider. They will probably just tell you to do one of the things that Jay suggests in his answer: either pick one of the two dates, or split it into two reimbursement requests. Ultimately, it doesn't really matter to anyone except you and the HSA provider.

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  • My HSA has a debit card which I use for, well actually I think I have used it 100% of the time. Any store that takes a card is assigned a "merchant code" to identify the type of product or service they sell. One or more of these codes are for medical services. So if I tried to use the HSA card at a sporting goods store, it would quickly be flagged as not a medical expense. I don't know how rigorous the system of assigning codes is. I've never had a legitimate medical expense incorrectly flagged as ineligible. Whether it would pass something that is in fact not legitimate, I don't know.
    – Jay
    Apr 4, 2023 at 15:50

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