Can a High Deductible Health Plan (HPHP) subscriber that has Employee + Spouse coverage enroll in a Health Savings Accounts (HSA) and contribute the full family contribution limit to their HSA if the employee has Medicare Part A?
Only the Medicare enrollment status of the account owner affects HSA eligibility; the Medicare enrollment status of dependents is not relevant. If an individual has family level HDHP coverage, then they can potentially contribute up to the full family amount of $7,200 for the 2021 calendar year (assuming they were eligible the full year).
Additional Information on Medicare/HSA Interactions: Turning 65 or otherwise becoming eligible for Medicare does not automatically make an individual ineligible for HSA contributions. Being eligible for and enrolling in Medicare does. An individual is no longer eligible to make or receive HSA contributions beginning with the first month that they are enrolled in Medicare. However, they can continue to use any funds that were contributed during the period they were eligible, even after they enroll in Medicare.
Important Note: Some individuals choose not to enroll in Medicare when they are first eligible, so they may continue contributing to an HSA. HSA account owners should be aware that if they later enroll in Medicare, the Centers for Medicare and Medicaid Services (CMS) will backdate the coverage start date up to six months. This can create an excess contribution issue if the individual was contributing to their HSA during that six-month period; individuals enrolling in Medicare past their original enrollment eligible date are encouraged to plan accordingly and speak to a tax advisor.