I have only a basic understanding of HSAs (I am a cpa) and client is asking me something that is beyond my knowledge base. Any help you could provide is appreciated.

The specific question from my client is:
"We have an employer with an insurance plan year of December - November.
Their deductible was set at $1100 beginning December 1, 2008 through
November 30, 2009. The minimum deductible amount changed to $1150 for
2009. Now, our system is telling us the accounts are not eligible because
the deductible is too low.

We contacted the employer (an insurance company) and they maintain their
plan IS eligible and our information is not correct. Can you provide any
guidance with this?"

I found this quote in an on-line article but unfortunately no citation to accompany it:

"Additionally, a fiscal year plan that satisfies the requirements for a high deductible health insurance plan on the first day of the first month of its fiscal year may apply that deductible for the entire fiscal year."

Can anyone tell me if this is true and if so, what is the IRS citation (Code, Regs, Rev Ruling, etc.)?

Notice 2004-50 includes a Q&A 86,which says "if a plan is qualified on the first day of the first month of the plan's year, it can stay an HDHP for 12 months, even if indexed amounts change. So the plan could keep the 2008 minimum deductible of 1100 (for individual coverage) until November 30, 2009 and remain a qualified HDHP.

Call me if you have additional questions.

Jim
Great Lakes HSA

Thanks, Jim!