Suppose two unmarried individuals each have independent family coverage HDHPs that provide coverage for both individuals. Irrelevant, but for simplicity, assume this family coverage is free of charge (perhaps sponsored by their respective employers).
Each individual qualifies for an HSA according to the requirements in IRS Publication 969:
- You must be covered under a high deductible health plan (HDHP), described later, on the first day of the month.
- You have no other health coverage except what is permitted under Other health coverage, later.
- You are not enrolled in Medicare.
- You cannot be claimed as a dependent on someone else's 2015 tax return.
The IRS has special "Rules for married people" (below), but this does not apply since the individuals are not legally married.
If either spouse has family HDHP coverage, both spouses are treated as having family HDHP coverage. If each spouse has family coverage under a separate plan, the contribution limit for 2015 is $6,650. You must reduce the limit on contributions, before taking into account any additional contributions, by the amount contributed to both spouses' Archer MSAs. After that reduction, the contribution limit is split equally between the spouses unless you agree on a different division.
What is the maximum that these individuals may contribute to their respective HSA accounts?