Can One Spouse Have an HSA and the Other an HRA?

Yes, one spouse can have an HSA while the other has an HRA, but only if the HRA is built or restricted so it doesn’t extend general medical coverage to the HSA-holding spouse before the High Deductible Health Plan deductible is met. A standard general-purpose HRA covers the employee’s spouse by default, and the IRS treats that coverage as disqualifying “other coverage” that ends HSA eligibility. The fix is choosing an HRA design the IRS has already blessed as compatible, or confirming in writing that the HRA is limited to the employee alone.

Why a Spouse’s HRA Usually Blocks HSA Contributions

HSA eligibility requires HDHP enrollment and no other health coverage that pays benefits before the HDHP deductible is satisfied.¹ The IRS reads “other coverage” broadly, and an HRA offered through a spouse’s employer counts if it can reimburse the HSA-holding spouse’s general medical bills.

Revenue Ruling 2004-45 makes the point directly: if your spouse’s employer funds a general-purpose HRA that covers you, you cannot contribute to an HSA, even if you never submit a claim.² What matters is entitlement, not use. As long as the plan documents permit the HRA to reimburse your medical expenses before your HDHP deductible is met, the IRS considers you covered by a non-HDHP plan.

Couples often miss this. One spouse enrolls in an employer HRA without thinking about the other’s HSA, and the household unknowingly makes ineligible contributions for months. Each excess dollar left in the HSA at year-end triggers a 6% excise tax under §4973, and that tax repeats every year the excess sits there.³

HRA Designs That Keep the HSA Intact

Not every HRA is disqualifying. The IRS has identified specific HRA designs that don’t count as other coverage because they don’t provide general medical benefits before the HDHP deductible is met.⁴ If your spouse’s HRA fits one of these categories, your HSA eligibility survives.

A limited-purpose HRA reimburses only dental, vision, and preventive care. These categories are excluded from the “other coverage” test under §223, so the HRA can cover both spouses without threatening HSA eligibility.
A post-deductible HRA pays nothing until the statutory minimum HDHP deductible has been met. The HRA’s internal deductible doesn’t need to match the HDHP’s, but no benefits can flow before the statutory floor is reached.
A suspended HRA is one the employee elects, before the coverage period, to shut off for general medical reimbursements. During the suspension, only preventive, dental, and vision items can be paid. Once the suspension ends, HSA contribution eligibility ends with it.
A retiree-only HRA reimburses only expenses incurred after retirement. While the employee is still working, it produces no current benefits and doesn’t interfere with HSA eligibility.

The suspended HRA is the most flexible option when a spouse’s employer offers nothing but a general-purpose plan. The election must be made before the HRA coverage period begins, and any general medical reimbursement taken after the suspension lifts will immediately disqualify further HSA contributions.²

Employee-Only Enrollment and the Plan Document

Design isn’t the only path. If the HRA-holding spouse enrolls in employee-only coverage and the plan documents explicitly exclude the spouse from reimbursement, the other spouse is not covered by the HRA and keeps HSA eligibility.⁴ The word to watch is “explicitly.” Many HRAs default to covering the employee’s spouse and dependents unless the plan says otherwise.

Ask the employer for the Summary Plan Description and read the eligibility section. You need written confirmation that the HRA does not reimburse expenses for anyone other than the enrolled employee. A verbal assurance from HR is not enough if the plan document reads differently. The IRS follows the plan language.

Carryover Balances

When a spouse drops general-purpose HRA coverage, leftover balances from prior years can still cause trouble. HRAs commonly roll unused funds forward, and if those carried-over dollars can still reimburse general medical expenses for the other spouse, the disqualifying coverage hasn’t actually ended. Before the new plan year starts, confirm that any carryover is exhausted, forfeited, or converted to a limited-purpose or post-deductible arrangement.

Grace Periods Versus Run-Out Periods

A grace period lets an HRA reimburse new expenses after the plan year ends. If your spouse’s plan has a grace period that could pay your medical bills, that coverage is disqualifying during the grace period even though the plan year technically closed. A run-out period only allows submission of claims for expenses already incurred during the prior plan year; it doesn’t create new coverage. The distinction is worth checking, because a grace period can cost months of HSA eligibility at the start of a new year.

ICHRA, QSEHRA, and the 2026 Bronze Plan Change

Two newer HRA types, the Individual Coverage HRA and the Qualified Small Employer HRA, follow the same core rule: if the HRA reimburses only insurance premiums and not out-of-pocket medical expenses, it won’t disqualify HSA contributions.⁵ An ICHRA designed to cover both premiums and general medical costs before the deductible is disqualifying, just like a traditional general-purpose HRA.

Starting January 1, 2026, the One, Big, Beautiful Bill Act treats all bronze and catastrophic health plans, whether purchased through a marketplace exchange or off-exchange, as HDHPs for HSA purposes.⁶ For couples, this means a spouse using a premium-only ICHRA or QSEHRA to buy a bronze plan can now pair that plan with an HSA, a combination that often wasn’t available before 2026.

If You Already Over-Contributed

Contributions made during months when a spouse’s HRA disqualified you are excess contributions subject to the 6% excise tax under §4973, calculated on the excess still in the account at year-end and repeating every year the excess remains.³

You can avoid the tax entirely by withdrawing the excess, plus any earnings on it, before the deadline for filing your return, including extensions.⁷ For the 2025 tax year, the primary deadline is April 15, 2026. If you already filed without withdrawing, you have a six-month window after the original due date to pull the money out and file an amended return with “Filed pursuant to section 301.9100-2” written at the top.

Don’t claim a deduction for the amount withdrawn, and report any earnings pulled out with the excess as income for the year of the withdrawal. Miss both deadlines and the 6% tax is owed on Form 5329, with interest running from the original due date.⁸

Losing Eligibility Doesn’t Touch Your Existing Balance

Losing HSA contribution eligibility does not freeze or forfeit the money already in your account. Existing HSA funds remain available tax-free for qualified medical expenses whether or not you are still eligible to contribute. The restriction applies only to new contributions. Your balance stays yours, continues to grow tax-free if invested, and does not expire. If your spouse’s HRA turns out to disqualify you, stop new contributions right away, then work on either fixing the HRA structure or cleaning up any excess already deposited.

1
Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts
2
Internal Revenue Service. Rev Rul 2004-45
3
Office of the Law Revision Counsel. 26 USC 4973 – Tax on Excess Contributions to Certain Tax-Favored Accounts and Annuities
4
Internal Revenue Service. Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans
5
Internal Revenue Service. IRS Notice 2026-05, Expanded Availability of Health Savings Accounts Under the OBBBA
6
Internal Revenue Service. Treasury, IRS Provide Guidance on New Tax Benefits for Health Savings Account Participants Under the One Big Beautiful Bill
7
Internal Revenue Service. Instructions for Form 8889
8
Internal Revenue Service. Instructions for Form 5330