How Much Can Spouses Contribute to Their Accounts When Both Are HSA-eligible?

This column is an excerpt (Question 50) from a book to be published later this year to help guide account owners, employers, benefits managers, and administrators understand Health Savings Account compliance issues. The format consists of a common question, an explanation in easy-to-understand English (often with an appropriate example), and a citation from government documents to support the answer. The book is designed to inform. It is not a legal document, and the contents should not be construed as legal advice.

Question: My wife and I are both HSA-eligible, and each of us has opened a Health Savings Account. How much can we contribute to our respective Health Savings Accounts?

Answer: You’re covered on a family plan, so your maximum contribution as a couple is $8,550 in 2025. The question is whether you (1) must divide that total using a fixed formula, (2) can split that total between the two accounts as you wish, or (3) can each contribute up to $8,550 into your respective accounts.

Congress explicitly addressed the married-couple scenario in the Health Savings Account legislation. Your total deposits to your accounts can’t exceed the statutory maximum annual contribution to a family contract and “shall be divided equally between them unless they [Author’s note: the spouses] agree to a different division.”

So, in 2025, you can split the $8,550 maximum family contribution (if you’re both HSA-eligible all 12 months of the year) as you wish between the two accounts. And if either of you is age 55 or older, you can deposit an additional $1,000 annually into your own Health Savings Account each year.

 Tips

 Most couples in this situation maintain just one account owned by the plan subscriber. There are sound reasons for doing so:

• Tax savings. The subscriber-spouse usually can make pre-tax payroll deductions through an employer’s Cafeteria Plan. These funds are deposited into the account before federal payroll (FICA) and income taxes and state income taxes are withheld. A subscriber can’t make pre-tax contributions to a spouse’s Health Savings Account, and, in most cases, the spouse’s employer won’t allow her to make pre-tax contributions to an account that’s not part of her employer’s Health Savings Account program. Contributions to the spouse’s account are limited to personal deposits, which she can deduct on her individual (or their joint) personal income tax return. She can recover federal and state income taxes levied on the funds contributed (except state income taxes in California and New Jersey), but not federal payroll taxes. Thus, on every $1,000 of personal contributions, an account owner loses the opportunity to retain up to $76.50 in payroll tax savings. That’s unfortunate, but the figure usually is a fraction of the income-tax savings.

• Administrative ease. Most couples try to simplify their financial lives. Since the subscriber spouse can reimburse his wife’s qualified expenses tax-free from his Health Savings Account and the couple can’t contribute more to a Health Savings Account just because they own a second account, a single account owned and managed by the subscriber spouse generally makes sense.

• Cost. Beyond the time required to manage a second account, couples may be subject to a monthly administrative fee that Health Savings Account providers often charge per account. Most couples wish to avoid the fee if the second account doesn’t allow them to make additional contributions or reimburse additional family members’ qualified expenses tax-free.

There are times, however, when it makes sense for both spouses to maintain their own Health Savings Accounts. Here are some specific situations:

• Catch-up contribution. The non-subscriber spouse is age 55 or older and eligible to make a catch-up contribution. A catch-up contribution must be deposited into a Health Savings Account owned by the person eligible to make the contribution. A wife who turns age 55 can’t deposit her catch-up contribution into her husband’s Health Savings Account. She must open her own.

• Older non-subscriber spouse. The subscriber can reimburse tax-free his spouse’s qualified medical, dental, and vision expenses and certain over-the-counter expenses tax-free, regardless of his or her age. But he can’t reimburse her Medicare premiums tax-free until he – the account owner – turns age 65. If his wife is older than he is, the couple must make sure that she has an account balance sufficient to reimburse her Medicare premiums tax-free until he turns age 65 and can reimburse them tax-free from his Health Savings Account (which has the larger balance). In this case, in addition to depositing her catch-up contributions into her account, she and her husband may agree to split a portion of the family contribution (even at the expense of losing the payroll tax savings that the husband realizes through pre-tax payroll contributions) to fund her account to reimburse her Medicare expenses until he turns age 65 and can reimburse her Medicare premium tax-free from his account.

• End of marriage. If the spouses are dissolving a marriage and working cooperatively toward that end, it may make sense for the wife to open her own Health Savings Account and for them to begin to split the family contribution to fund her account. The husband won’t be able to reimburse tax-free the qualified expenses that she incurs once they file for divorce. If the wife has established and funded her own account with some of or all the family contribution, plus catch-up contributions if she’s age 55 or older, she can reimburse her qualified expenses tax-free from her account.

IRS Notice 2004-50:

Q-32. How may spouses agree to divide the annual HSA contribution limit between themselves?

A-32. Section 223(b)(5) provides special rules for married individuals and states that HSA contributions (without regard to the catch-up contribution) “shall be divided equally between them unless they agree on a different division.” Thus, spouses can divide the annual HSA contribution in any way they want, including allocating nothing to one spouse.

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The content of this column is informational only. It is not intended, nor should the reader construe the content, as legal advice. Please consult your personal legal, tax, or financial counsel for information about how this information applies to you or your entity.

HSA Question of the Week is published every week, alternating every other Wednesday with HSA Wednesday Wisdom and every other Monday with HSA Monday Mythbuster.