Health Savings Account Contributions, Distributions Declined During the Pandemic

The EBRI HSA Database also shows very few account holders are investing their savings.

­Average annual individual contributions to health savings accounts (HSAs) fell last year after reaching an all-time high in 2019, going from $2,041 to $1,995, according to the Employee Benefit Research Institute (EBRI) HSA Database.

The database also shows that average annual employer contributions fell between 2019 and 2020, from $918 to $864 on average—a 6% decline. Total contributions—i.e., from both individuals and employers—decreased from $2,959 to $2,859, or 3%, between 2019 and 2020.

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EBRI says individuals might be saving less in their HSAs because of COVID-19. “It’s possible that as unemployment increased, account owners reduced contributions,” it says in an Issue Brief. “Furthermore, the decline … may be correlated with the decline in use of health care services that was due to COVID-19.”

As a result of the pandemic, patients delayed or missed doctor visits and preventive screenings, and depression, anxiety and substance use disorders surged, according to the Business Group on Health’s 2022 Large Employers’ Health Care Strategy and Plan Design Survey. With that in mind, employers anticipate seeing an increase in medical services, late-stage cancer diagnoses and greater numbers of people with long-term mental health and substance use issues for years to come.

EBRI speculates that the lower use of health care services is also the reason average annual distributions from HSAs fell to an all-time low of $1,714 last year.

Investing HSA Savings

Data from the EBRI HSA Database show that very few account owners invest their HSA balance, leaving their savings in cash. Last year, 9% of accounts were being invested, up from 2% in 2011.

A report from Devenir says investing HSA savings is key to building account balances. According to “2019 Year-End Devenir HSA Research Report,” HSA investment accounts have an average total balance of $16,012—seven times larger than a non-investment holder’s average account balance.

EBRI says there could be several reasons for the low percentage of account owners investing their HSA savings. First, in order to invest, account owners often must have a minimum account balance. As EBRI’s report shows that most accounts are new, many will be too small to take advantage of investment. Second, account owners may be unaware of the option to invest.

In addition, EBRI says, account owners may be using the account only to pay for out-of-pocket expenses and therefore may want to avoid short-run risks with investment fluctuations. Or they may be trying to build up a balance large enough to cover their deductible before investing.

However, EBRI found that when accounts are invested, that means most of the money in them. Among open accounts with investments, 74% of the balances were invested. Generally, the longer an account has been open, the larger the percentage of the balance that is invested—e.g., 77% of the balances of accounts open for 10 years.

More findings from the EBRI HSA Database appear in its Issue Brief “Trends in Health Savings Account Balances, Contributions, Distributions, and Investments and the Impact of COVID-19,” which can be found at http://www.ebri.org/hsa-long.

Allowing for After-Tax Contributions in a 401(a) Plan

Experts from Groom Law Group and CAPTRUST answer questions concerning retirement plan administration and regulations.

I read with great interest your Ask the Experts column on having an after-tax contribution feature in a 403(b) plan. I work for a public university that is considering adding after-tax contributions to both its 401(a) and 403(b) plans, as we do not have ACP testing in our plans, which might normally preclude having an after-tax contribution feature. The previous column provides all the info we need to evaluate adding a 403(b) after-tax contribution. However, is there anything different that we need to consider if we add the feature to our 401(a) plan?”

Charles Filips, Kimberly Boberg, David Levine and David Powell, with Groom Law Group, and Michael A. Webb, senior financial adviser at CAPTRUST, answer:

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All of the same issues that we point out in the 403(b) column apply in the 401(a) plan context (ACP testing, which, as you indicate, does not apply to governmental plans, employer contributions limiting after-tax contributions, withdrawal restrictions/taxation, etc.). See Code sections 401(a)(4), 401(a)(5)(G), 415(c), 401(k)(2)(B)(i) and 72(t). Like 403(b) plans, voluntary after-tax contributions to a 401(a) defined contribution (DC) plan, when combined with other contributions, are limited under 415(c) to the lesser of 100% of the participant’s compensation as defined under the plan or $58,000 in 2021. Note that the limit is the same whether the 401(a) plan is a money purchase or profit-sharing plan.

The primary difference between your 401(a) plan and 403(b) plan is that only the 403(b) plan may allow for pre-tax/Roth elective deferrals (unless you have a grandfathered 401(k) arrangement)), so the opportunity to make after-tax contributions may be greater in the 401(a) plan, depending on employer contributions, since there are no elective deferrals present that would otherwise reduce the amount of after-tax contributions a participant could make due to application of the 415(c) limit.

 

NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.

Do YOU have a question for the Experts? If so, we would love to hear from you! Simply forward your question to Rebecca.Moore@issgovernance.com with Subject: Ask the Experts, and the Experts will do their best to answer your question in a future Ask the Experts column.

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