Mid-year switch from HSA to FSA during employer's February open enrollment - contribution timing question
My company has a weird benefit year that runs Feb 1st to Jan 31st instead of the calendar year. We're heading into open enrollment soon, and they've just introduced this awesome copay insurance plan with an FSA option that I want to jump on. I've been on an HSA-eligible plan for like 5+ years now. I understand I can stop my HSA contributions, enroll in the new copay plan, and start the FSA beginning 2/1 since this is during our official open enrollment period. Here's my concern though - do I need to make absolutely sure there's no HSA deduction in my 1/16-1/31 paycheck (which gets paid on 2/6)? I will have already made 2 HSA contributions at the maximum level from the first two January paychecks. Our HR department is telling me I can still make that final contribution, but last year they told employees they could contribute the full annual HSA max in January and then switch to an FSA in February without any tax issues - which I know is completely wrong. So I don't trust anything they say at this point. Our payroll company is a complete disaster, so if I need to fight with them to cancel that last HSA contribution, I need to start now. I'm pretty sure I need to stop it, but want to confirm.
21 comments


Vanessa Figueroa
You're absolutely right to question this. When switching between HSA and FSA, the timing is crucial for tax compliance. Here's what you need to know: You cannot contribute to both an HSA and an FSA in the same month (with very limited exceptions for "limited purpose" FSAs). Since your last January paycheck would be processed on February 6th, but would count as a contribution for January, you technically could make that contribution since you're still HSA-eligible for all of January. However, there's a potential issue - if your FSA coverage begins on February 1st, you will be covered by the FSA on the date that HSA contribution is actually made (Feb 6th). This creates a gray area that could cause headaches. The safest approach is to stop that final HSA contribution to avoid any potential compliance issues. While technically the contribution is for January when you were eligible, the physical timing of the contribution occurring in February when you have active FSA coverage could create confusion during tax filing.
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Abby Marshall
•But if the contribution is for January when they were HSA eligible, shouldn't it be fine regardless of when the physical money moves? I thought it's about the period the contribution is designated for, not the actual transaction date?
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Vanessa Figueroa
•The IRS generally looks at the date the contribution is actually made, not just the period it's designated for. While employers do have until their tax filing deadline to make contributions for the previous year, for individual contributions, it's cleaner to avoid this overlap. The concern is that having an active FSA on the date when the HSA contribution physically happens could potentially flag in IRS systems. While you could probably defend it since the contribution is for January, why risk the potential audit trigger? It's safer to just skip that last contribution and avoid any possible complications entirely.
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Sadie Benitez
I went through the same situation last year and found taxr.ai really helpful for figuring out the HSA/FSA transition rules. Their system analyzed my specific benefit enrollment dates and payroll schedule, then gave me a customized report explaining exactly what I needed to do to avoid issues. Check out https://taxr.ai if you want a definitive answer based on IRS rules instead of trusting HR. The tool flagged that my HR's advice would have created a tax violation because of the timing of my contributions - sounds similar to your situation. It also explained how to document everything properly in case of questions from the IRS later. Saved me from making a mistake that would've been hard to fix.
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Drew Hathaway
•How does taxr.ai actually work? I've never heard of it and I'm skeptical of online tax tools since I got burned by a free one a few years ago. Do you upload your pay stubs or something?
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Laila Prince
•Did it actually save you money or just give peace of mind? My company's HR also gives terrible advice about benefits timing but I've never had the IRS question anything. Wonder if it's worth bothering with a service for this.
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Sadie Benitez
•You just answer questions about your specific situation - in this case, details about your benefit periods, enrollment dates, and payroll schedule. You don't need to upload actual pay stubs, but you can add documents if you want their experts to review them. It's completely different from the automated tax filing tools. It saved me both money and headaches. In my case, I would have had to amend my tax return and pay penalties if I'd followed HR's advice. The service cost way less than what I would have paid in penalties, not to mention the time I would have wasted fixing everything. Plus, I got clear documentation explaining my situation that I keep with my tax records in case of questions later.
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Drew Hathaway
Thanks for recommending taxr.ai! I was skeptical at first but decided to give it a try since my situation was similar. Uploaded my benefit enrollment details and pay schedule info, and within a day I got a detailed analysis explaining exactly how to handle the transition. The report showed that I needed to stop my HSA contributions completely before my FSA became active, and included the specific IRS regulations that applied to my situation. The tool also generated a letter I could give to my payroll department explaining why the change was necessary. My HR initially pushed back but stopped when I showed them the documented IRS rules! Definitely worth it for the peace of mind and avoiding potential tax headaches down the road.
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Isabel Vega
If you're having trouble getting through to your HR or payroll department on this, I'd recommend using Claimyr to get an IRS agent on the phone directly. I had a similar HSA/FSA issue last year that my company messed up, and I couldn't get a straight answer from anyone. Used https://claimyr.com to get through to the IRS (the video at https://youtu.be/_kiP6q8DX5c shows how it works) and got clarification directly from them. Instead of waiting on hold for hours, Claimyr got me connected with an IRS agent in about 20 minutes who confirmed exactly how to handle the transition timing and documentation requirements. The agent even emailed me the relevant tax code sections that I forwarded to my HR department to get them to stop the incorrect contribution.
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Dominique Adams
•How does this actually work? I thought it was impossible to get through to the IRS these days. Is this just paying someone to wait on hold for you?
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Marilyn Dixon
•Sounds like a scam to me. The IRS doesn't just answer random tax hypotheticals over the phone, and they definitely don't email tax code sections to people. I've tried calling the IRS multiple times and they always say they can't provide tax advice.
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Isabel Vega
•It's basically a service that navigates the IRS phone system and waits on hold for you. Once they reach an agent, your phone rings and you're connected directly with the IRS. You're not paying for tax advice - you're paying to skip the notorious hold times that can be 2+ hours. The IRS agents absolutely can and do provide clarification on tax rules (not the same as personalized tax advice). In my case, the agent confirmed the rules about HSA and FSA timing and referenced the specific sections of the tax code I needed. They didn't email me directly - I took notes during the call about which sections to look up, then found the official documentation myself afterward. I just meant I had official information I could show my HR department rather than just my interpretation.
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Marilyn Dixon
OK I need to eat some crow here. After posting my skeptical comment, I decided to try Claimyr myself since I've been trying to reach the IRS about an issue with my HSA contributions from last year. The service actually worked exactly as advertised. I got a call back in about 25 minutes and was connected with an IRS representative who was super helpful. They walked me through the exact rules for HSA/FSA timing and even put notes in my file about the conversation in case there were any questions about my tax return. The representative confirmed that you cannot have both an HSA contribution and FSA coverage active on the same day - so that last contribution on Feb 6th would indeed be problematic even if it's for January. Seriously worth the money to get a definitive answer directly from the source instead of playing tax roulette based on HR's bad advice.
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Louisa Ramirez
Former benefits administrator here. Your instincts are right - you absolutely need to stop that last HSA contribution. The problem is that FSA eligibility makes you HSA-ineligible, regardless of whether you actually use the FSA or not. Since that contribution would physically happen on 2/6, when you're already FSA eligible, it creates a compliance issue. Your HR department is confusing two different scenarios. They're thinking about the rule that lets you make prior-year HSA contributions until April 15th, but that only applies if you remained HSA-eligible. Once you have FSA coverage, you can't make any HSA contributions, even for periods when you were previously eligible.
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Diez Ellis
•Thanks for the clear explanation! Just to make sure I understand - is this still true even though the contribution would be processed through payroll and specifically coded for the January pay period? Or does the physical date of the money transfer override everything else?
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Louisa Ramirez
•The physical date matters here. The IRS looks at when the contribution actually occurs, not just how it's coded in payroll. Even though the contribution would be allocated to January, the fact that it physically happens on February 6th when you have active FSA coverage is what creates the problem. I've seen this exact situation trigger compliance issues during audits. The safest approach is to make sure your last HSA contribution happens while you're still HSA-eligible without any FSA coverage. The payroll coding unfortunately doesn't protect you here - it's about when the money actually moves.
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TommyKapitz
I work in benefits administration and deal with this every year. Here's a simple rule: NEVER have overlapping HSA and FSA coverage, even for a single day. The safest approach is to: 1) Terminate HSA contributions with your last January paycheck (the one paid on/before Jan 31) 2) Start FSA with your first February paycheck Technically, your HSA contribution limit for 2025 will be prorated for just January, so you're only eligible for 1/12 of the annual limit anyway during this year of transition. If you've already maxed out January's prorated amount with your first two January paychecks, you're already at your limit.
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Angel Campbell
•Are you sure about that 1/12 proration? I thought the HSA limit wasn't prorated as long as you're eligible on December 1st and satisfy the testing period. But if you lose eligibility early in the year, do you actually need to prorate?
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Clarissa Flair
•You're right to question that - the proration rule is more complex. If you're HSA-eligible on December 1st, you can contribute the full annual amount regardless of when during the year you became eligible (this is called the "last month rule"). However, if you lose HSA eligibility before December 1st, then yes, your contribution limit gets prorated based on the number of months you were eligible. In the original poster's case, since they're switching to FSA coverage starting February 1st, they won't be HSA-eligible on December 1st, so their 2025 HSA contribution limit will indeed be prorated to just January (1/12 of the annual limit). If they've already contributed more than that 1/12 amount in their first two January paychecks, they'd actually have excess contributions that need to be corrected.
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Jamal Carter
This is a great example of why you can't trust HR departments with complex tax rules! I had a similar situation two years ago where my company's benefits team gave me completely wrong information about HSA/FSA transitions. The key issue here is that once you have FSA coverage starting February 1st, you become HSA-ineligible immediately. This means any HSA contribution made after that date - even if it's coded for January - creates a compliance problem because the physical contribution occurs when you're no longer eligible. Plus, as others have mentioned, since you're losing HSA eligibility before December 1st, your 2025 contribution limit will be prorated to just 1/12 of the annual maximum (since you're only eligible for January). If you've already contributed more than that amount in your first two January paychecks, you'll need to request a return of excess contributions anyway. My advice: Stop that final HSA contribution immediately, and double-check that your January contributions don't exceed the prorated limit. It's much easier to prevent these issues than to fix them after the fact on your tax return.
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Leo McDonald
•This is really helpful information! I'm dealing with a similar transition situation and hadn't realized the proration issue. Quick question - if someone has already over-contributed in January before realizing the 1/12 limit applies, what's the best way to get those excess contributions back? Do you just contact the HSA provider directly, or does it have to go through payroll since it was a payroll deduction?
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