Upon leaving my previous employer my HSA custodian started dinging me with a monthly "administrative billing fee". I've taken no non-qualified distributions from the HSA but received a 1099-SA with a gross distribution dollar amount matching the amount of the monthly fees for the year. My gut reaction is that the fees probably shouldn't be counted as unqualified distributions and the following section from IRS publication 969, p9 (2013 version link) seems to suggest I'm right to question this practice:
TIP: HSA administration and maintenance fees withdrawn by the trustee are not reported as distributions from the HSA.
Is the monthly "administrative billing fee" imposed by my HSA custodian mischaracterized as a gross distribution, subject to the 20% penalty?
UPDATE: My HSA administration sent a corrected 1099-SA that corrected the monthly fee being counted as an unqualified distribution.