Can You Have an HRA and HSA at the Same Time?

Yes, you can have an HRA and an HSA at the same time, but only if the HRA is structured so it cannot pay for general medical expenses before you satisfy your High Deductible Health Plan deductible. A standard, general-purpose HRA disqualifies you from contributing to an HSA even if you never file a single claim. Several IRS-approved formats — limited-purpose, post-deductible, suspended, and retirement HRAs — preserve HSA eligibility by restricting what the HRA reimburses, when it pays, or both.

Why a General-Purpose HRA Blocks HSA Contributions

HSA eligibility turns on a “no other coverage” rule. To contribute, you must be enrolled in an HDHP and have no other health arrangement that pays for medical costs before the HDHP deductible is met.¹ A standard HRA reimburses medical expenses from the first dollar you spend, which is exactly the kind of coverage the statute forbids.

What matters is availability, not use. The IRS treats a general-purpose HRA as disqualifying coverage regardless of whether you actually request reimbursement.² If you contribute to an HSA during any month you are covered by such an HRA, those contributions are excess and subject to a 6% excise tax each year they remain in the account.³

HRA Formats That Preserve HSA Eligibility

Four HRA designs are compatible with an HSA. Each one either narrows the categories of expense the HRA can pay or delays payment until after you have met the HDHP deductible.

Limited-Purpose HRA

A limited-purpose HRA reimburses only dental, vision, and preventive care expenses. Because those categories do not count as general medical coverage under the HDHP rules, this format leaves your HSA eligibility intact and you can still contribute the full annual limit.¹ Preventive services like annual physicals and immunizations are explicitly permitted, even before you meet the HDHP deductible.

Post-Deductible HRA

A post-deductible HRA holds back all general medical reimbursements until you have satisfied at least the statutory minimum HDHP deductible. For 2026, that minimum is $1,700 for self-only coverage or $3,400 for family coverage.⁴ Once you cross that threshold, the HRA can begin reimbursing expenses, including coinsurance, without affecting your HSA status.⁵ The HRA’s own deductible does not have to match the HDHP’s, but no benefits can be paid before the statutory minimum is reached.

Suspended HRA

If your employer offers a general-purpose HRA, you can elect to suspend it before a coverage period begins. During the suspension, the HRA pays nothing except preventive care and permitted coverage like dental and vision. That removes the disqualifying coverage and restores HSA eligibility for the suspension period.¹ When the suspension ends, so does your ability to contribute.

Retirement HRA

A retirement HRA only reimburses medical expenses incurred after you retire. Because the funds are unavailable while you are working, this format does not disqualify you from contributing to an HSA during your working years. Once you retire and the HRA activates, HSA contributions stop.¹

ICHRA and QSEHRA

Two newer HRA types follow the same compatibility logic with a few specifics of their own.

Individual Coverage HRA

An ICHRA lets an employer reimburse employees for individual health insurance premiums instead of offering a group plan. An ICHRA that reimburses only premiums does not disqualify you from HSA contributions, as long as you are enrolled in an HDHP and have no other disqualifying coverage.² An ICHRA that can also reimburse first-dollar cost-sharing expenses is not HSA-compatible; it behaves like a general-purpose HRA. Employers wanting both features generally have to restrict reimbursements to premiums only or set the ICHRA up as a limited-purpose or post-deductible arrangement.⁶

Qualified Small Employer HRA

A QSEHRA is available to small employers with fewer than 50 employees that do not offer a group health plan. HSA compatibility depends on what the QSEHRA is permitted to reimburse. If it can pay any medical expense, including deductibles and copays, it is disqualifying coverage and you cannot contribute to an HSA while enrolled. If it is limited to premiums, or to premiums plus permitted coverage like dental and vision, your HSA eligibility is preserved.⁷

When a Spouse’s HRA Is the Problem

Your spouse’s HRA can wreck your HSA eligibility without you ever touching it. If the HRA at your spouse’s job covers your entire family, you are generally considered to have disqualifying coverage even when you have your own HDHP and never submit a claim. The statute asks whether you are “covered under” a non-HDHP arrangement, not whether you actually receive benefits from it.⁸

Three fixes can restore your eligibility:

Convert the HRA to a limited-purpose or post-deductible format, which eliminates the disqualifying coverage for both spouses.
Amend the HRA plan documents to exclude the employee’s spouse.
Restrict the HRA to employee-only coverage, removing family members entirely.

If you are not sure whether your spouse’s HRA covers you, ask for a copy of the Summary Plan Description. The plan documents, not your spouse’s enrollment elections, determine whether you are considered covered.

The Grace Period Trap When Switching Plans

Moving from a general-purpose HRA to an HSA-eligible setup at the start of a new plan year is not always clean. If the old HRA includes a grace period, typically up to 2½ months after the plan year ends, during which you can still be reimbursed for prior-year expenses, you generally cannot contribute to an HSA until the first day of the month after that grace period closes.⁹

Three moves close the gap. If your HRA balance is zero on the last day of the plan year, you can waive participation starting the first day of the new plan year. The employer can terminate the general-purpose HRA for all employees. Or the employer can convert the HRA to a limited-purpose or post-deductible design before the new plan year begins.⁹ Without one of those steps, you can lose several months of HSA contribution eligibility at the start of the year.

Fixing HSA Contributions Made During HRA Coverage

If you already contributed to an HSA during a period when a disqualifying HRA was in place, those contributions are excess and need to be corrected. Two windows let you avoid the 6% excise tax.

The cleaner option is to withdraw the excess, along with any earnings on it, by your tax return due date, including extensions. The earnings go into your gross income for the year of the excess contribution, and if you are under 59½, the earnings are also hit with the 10% additional tax on early distributions.¹⁰

If you already filed without correcting, you have a second chance: withdraw the excess within six months of the original filing deadline (not counting extensions) and file an amended return with “Filed pursuant to section 301.9100-2” at the top, reporting the related earnings and explaining the withdrawal.¹⁰ Miss both windows and the 6% excise tax applies each year the excess sits in the account, reported on Form 5329, Part VII.³

1
Internal Revenue Service. Publication 969 – Health Savings Accounts and Other Tax-Favored Health Plans
2
Internal Revenue Service. Internal Revenue Bulletin 2019-28 – Section: Interaction of Individual Coverage HRAs and HSAs
3
Office of the Law Revision Counsel. 26 USC 4973 – Tax on Excess Contributions to Certain Tax-Favored Accounts
4
Internal Revenue Service. Notice 2026-05 – Expanded Availability of Health Savings Accounts
5
Internal Revenue Service. Revenue Ruling 2004-45
6
Federal Register. Health Reimbursement Arrangements and Other Account-Based Group Health Plans
7
Internal Revenue Service. Notice 2017-67 – Qualified Small Employer Health Reimbursement Arrangements
8
Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts
9
Internal Revenue Service. Notice 2007-22 – Health Savings Accounts
10
Internal Revenue Service. Instructions for Form 5329 – Additional Taxes on Qualified Plans and Other Tax-Favored Accounts