You can generally keep contributing to an HSA under an ICHRA — but only if the ICHRA is set up one specific way. Here's the catch.
A lot of people moving to an ICHRA already have an HSA and want to keep using it. Good news: it's generally possible. But there's a rule that trips people up every year.
The IRS says you can't fund an HSA if you have "other coverage" that pays medical bills before the HDHP deductible. An ICHRA that reimburses only premiums doesn't count as other coverage — you're fine. But an ICHRA that also reimburses deductibles, copays, and prescriptions generally does count, and it disqualifies you from HSA contributions.
| Your ICHRA reimburses… | HSA contributions? |
|---|---|
| Premiums only | Generally allowed |
| Premiums + medical expenses, but only after you've met the HDHP deductible ("post-deductible ICHRA") | Generally allowed |
| Premiums + medical expenses from dollar one | Generally not allowed |
Some employers offer two versions and let HSA-minded employees pick the premium-only one. Ask.
Your existing HSA balance is still yours — you can spend it on qualified expenses tax-free forever. What stops is new contributions while you're covered by the disqualifying ICHRA. If you contributed by mistake, that's generally fixable before the tax deadline; talk to a tax professional.
Often yes, for the same reasons as always: lower premiums (which may leave room in your allowance), triple tax advantage, and the money rolls over. The trade-off is a higher deductible. If you take regular prescriptions or expect a procedure, a gold plan paid mostly by your allowance may beat the HSA math. Run both.