< Back to IRS

Cedric Chung

Understanding HSA Last Month Rule for 2025 Contribution Limits

So I'm a bit confused about the HSA last month rule and hoping someone can break it down for me. Here's my situation: For the first 9 months of 2024, I didn't have an HDHP at all. Then in October 2024, I got a new job with benefits and enrolled in a Family HDHP for the last 3 months of the year (Oct-Dec). Starting January 1st, 2025, my situation is changing again, and I'll be switching to a Single HDHP coverage for all of 2025. My question is: For the 2024 tax year, am I allowed to contribute the full family maximum of $8,300 to my HSA due to the last month rule? I know there's something about being "eligible on the first day of the last month" but I'm not clear if that means I can contribute the full family amount even though I only had the family plan for 3 months. And does it matter that I'm switching to single coverage in 2025? I'm trying to figure this out before tax deadlines so I can maximize my contribution if possible. Thanks for any help!

Talia Klein

•

Yes, under the HSA last month rule, if you're eligible on December 1st of a tax year, you can contribute up to the full annual statutory maximum for the type of coverage you had on that date. Since you had Family HDHP coverage on December 1, 2024, you could technically contribute the full $8,300 family maximum for 2024. However, there's a very important catch that many people miss: the "testing period." If you use the last month rule, you must maintain HDHP coverage for the entire following year (January through December 2025). If you don't maintain eligible HDHP coverage for that entire testing period, the excess contribution amount (beyond what you would have been eligible for based on actual months of coverage) becomes taxable income AND is subject to an additional 10% penalty. Since you're switching to Single coverage in 2025, you're still meeting the testing period requirement as long as you maintain that Single HDHP coverage all year. The type of coverage can change, but you must remain HDHP-eligible throughout the testing period.

0 coins

Cedric Chung

•

Thank you for the explanation! So if I understand correctly, I can contribute the full $8,300 for 2024 even though I only had the Family HDHP for 3 months, but I have to keep some type of HDHP through all of 2025 to avoid penalties? And just to clarify, if I did a pro-rated amount instead (3/12 of the family maximum), would I still need to worry about the testing period? Or is that only if I do the full contribution under the last month rule?

0 coins

Talia Klein

•

Yes, you can contribute the full $8,300 family maximum for 2024 as long as you maintain HDHP coverage (either family or single) throughout all of 2025 to satisfy the testing period requirement. If you choose to do a pro-rated contribution instead (which would be 3/12 of $8,300 for the family coverage months), then you would not need to worry about the testing period at all. The testing period only applies when you take advantage of the last month rule to contribute more than your pro-rated amount. The pro-rated approach is safer if you're not 100% certain you'll maintain HDHP coverage for all of 2025.

0 coins

After struggling with this exact HSA last month rule situation last year, I found an amazing tool that saved me from making a costly mistake. I used https://taxr.ai to analyze my HSA eligibility based on my coverage changes, and it immediately flagged the testing period requirement that I would have missed. The tool reviewed my specific situation where I had switched coverage types mid-year, calculated my maximum contribution options (both prorated and full-year under the last month rule), and warned me about the testing period requirements. It even estimated what my potential tax penalty would be if I failed to maintain coverage. Saved me from potentially owing hundreds in penalties!

0 coins

PaulineW

•

Does taxr.ai handle other HSA-related situations? I'm wondering because my employer contributes to my HSA, and I'm not sure how that affects my personal contribution limits. Also, does it give advice on whether it's better to do the full contribution or the pro-rated amount?

0 coins

I'm skeptical about these tax tools. How does it actually know about future coverage? Like if you use the last month rule now, how would it know if you'll maintain coverage through next year? Seems like it would just be guessing.

0 coins

Yes, the tool definitely handles employer contributions! It asks for any employer HSA contributions and factors those into your personal contribution limit calculations. That was actually super helpful for me because my employer contributes quarterly, and I needed to adjust my personal contributions accordingly. It also presents both options (prorated vs. full contribution under last month rule) with pros and cons of each approach. For your question about future coverage, it doesn't predict the future, but it explains the testing period requirements clearly and gives you a "what-if" scenario tool that shows potential penalties if your coverage changes. This helped me decide whether the risk was worth taking in my situation, since I wasn't 100% sure about keeping my job through the end of the year.

0 coins

Just wanted to update - I tried taxr.ai after my skeptical comment above, and I have to admit it was actually really helpful. I uploaded my insurance docs and it confirmed I qualified for the last month rule but warned me about the testing period requirement. What impressed me was it did the math showing exactly how much I'd owe in penalties if I failed the testing period (way more than I expected). It also showed me that my employer's $1,200 contribution needed to be subtracted from my maximum, which I totally would have missed. Ended up saving me from overcontributing by about $1,500 which would have meant dealing with excess contribution penalties. Surprisingly good tool for something I was initially skeptical about.

0 coins

Chris Elmeda

•

If you're having trouble getting clear information from the IRS about HSA last month rules (their publication 969 is confusing at best), you might want to try Claimyr at https://claimyr.com. I was stuck on this exact issue last year and couldn't get anyone at the IRS on the phone for weeks. Claimyr got me connected to an IRS agent in about 15 minutes who confirmed my understanding of the last month rule and testing period. They have this system where they navigate the IRS phone tree for you and call you back when they have an agent on the line. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c I was particularly concerned because I had used the last month rule but then unexpectedly lost my HDHP coverage during the testing period, and I needed to understand exactly how to report that on my taxes.

0 coins

Jean Claude

•

How much does this service cost? Seems like something the IRS should provide for free instead of making us pay just to talk to them.

0 coins

Charity Cohan

•

This sounds fishy to me. How do they get you through faster than regular people? The IRS wait times are terrible for everyone. I've heard horror stories of people waiting on hold for 2+ hours only to get disconnected.

0 coins

Chris Elmeda

•

The service doesn't help you skip the line - they essentially wait in line for you using an automated system. So instead of you personally sitting on hold for hours, their system does it, then calls you when they've reached an agent. It saved me from having to sit through all those "your call is important to us" messages and horrible hold music. Regarding how they get through faster, they don't - they just handle the waiting part for you. In my experience, they used some technology that keeps trying different IRS menu options and times of day until they get through. When I tried calling myself, I kept getting the "call volume too high, try again later" message, but they managed to get through by trying repeatedly at optimal times.

0 coins

Charity Cohan

•

I have to publicly eat my words about Claimyr. After my skeptical comment, I figured I'd test it because I had some complex HSA questions. The regular IRS line had a "call back in 3 business days" message when I tried myself on Monday. Used Claimyr on Tuesday and they got me through to an IRS tax specialist in about 40 minutes. The agent walked me through the HSA testing period calculation worksheet and confirmed that switching from family to single coverage during the testing period is actually allowed as long as you maintain some form of HDHP coverage. For anyone dealing with HSA last month rule questions, getting direct confirmation from the IRS was actually invaluable since there's so much conflicting advice online. They even emailed me a call reference number so I have proof of the guidance I received in case of audit.

0 coins

Josef Tearle

•

Just a heads up that the HSA contribution limits for 2025 will be increasing again. The IRS announced that the family coverage maximum will be $8,550 (up from $8,300 in 2024) and single coverage will be $4,250 (up from $4,150). This matters for your testing period calculation - if you're using the last month rule for 2024 with family coverage but switching to single in 2025, make sure you're maintaining HDHP coverage through all of 2025, but your contribution limit for 2025 would be the single coverage amount of $4,250.

0 coins

Cedric Chung

•

Thanks for sharing the updated numbers! So does that mean if I stay HDHP-eligible all through 2025 with single coverage, I can contribute the full $8,300 for 2024 (based on December 2024's family coverage) AND also contribute $4,250 for 2025 (based on single coverage)? That sounds like a great opportunity to catch up on retirement savings.

0 coins

Josef Tearle

•

Yes, that's exactly right! You can contribute the full $8,300 for 2024 tax year (based on your December 2024 family coverage status) and then also contribute up to $4,250 for the 2025 tax year with your single coverage. It's a great opportunity to maximize your tax-advantaged savings. Just remember you have until April 15, 2025 to make your 2024 contributions, and until April 15, 2026 to make your 2025 contributions. Many people don't realize they can contribute for the previous tax year during the first few months of the next year, which gives you some flexibility with cash flow.

0 coins

Shelby Bauman

•

Has anyone here actually been audited for the HSA last month rule? I'm wondering how strict the IRS is about the testing period if something unexpected happens like job loss.

0 coins

Quinn Herbert

•

I wasn't specifically audited, but I did have to deal with this when I unexpectedly lost my job 6 months into the testing period. The IRS is very clear about this - if you fail the testing period for ANY reason, even job loss or other things outside your control, you have to report the "excess" contribution as income and pay the 10% penalty. I had to file Form 8889 showing the calculation. The only exception I know of is if you become disabled or die during the testing period. Otherwise, it's a strict requirement. It ended up costing me about $850 in additional taxes and penalties, which was painful.

0 coins

This is such a helpful thread! I'm in a similar situation but with a twist - I had individual HDHP coverage for the first 8 months of 2024, then switched to family coverage in September when I got married. So I had family HDHP on December 1st, 2024. From what I'm reading here, I should be able to contribute the full family maximum of $8,300 for 2024 under the last month rule, as long as I maintain some form of HDHP coverage through all of 2025 (which I plan to do with continued family coverage). But here's my question - since I actually had HDHP coverage for the entire year (just different types), does that make the testing period requirement less risky for me? Or is it the same risk as someone who only had coverage for part of the year? I'm trying to decide between the safe pro-rated approach vs. taking advantage of the full contribution amount.

0 coins

Great question! Your situation is actually more favorable than someone who only had partial-year coverage. Since you maintained HDHP eligibility for the entire 2024 tax year (even though you switched coverage types), you're in a much stronger position. The testing period requirement is the same regardless - you still need to maintain HDHP coverage through all of 2025. However, your risk is lower because you've already demonstrated a full year of HDHP commitment in 2024, which suggests you're likely to maintain it in 2025 as well. The fact that you had continuous HDHP coverage also means you could have contributed more throughout the year if you had wanted to, rather than having to rely solely on the last month rule. You could contribute the individual maximum for January-August, then the family maximum for September-December. But using the last month rule to contribute the full $8,300 family maximum is definitely simpler from a calculation standpoint. Given that you're planning to continue family coverage in 2025 and you've shown a pattern of maintaining HDHP coverage, I'd say the full contribution under the last month rule is a reasonable choice for your situation. Just make sure you're confident about maintaining that HDHP coverage through December 2025!

0 coins

Miguel Diaz

•

This is really helpful information for understanding the HSA last month rule! I've been following this discussion and wanted to add one important point that hasn't been mentioned yet - make sure you're also aware of the catch-up contribution rules if you're 55 or older. For 2024, if you're 55+ and eligible, you can contribute an additional $1,000 on top of the regular limits. So if you qualify for the full family maximum of $8,300 under the last month rule AND you're 55 or older, you could potentially contribute up to $9,300 for 2024. The catch-up contribution follows the same last month rule logic - if you were 55 on December 1, 2024, you can make the full catch-up contribution for the year, subject to the same testing period requirements. Just wanted to make sure folks don't miss out on that extra tax-advantaged savings opportunity if they qualify!

0 coins

Thanks for bringing up the catch-up contributions! That's a really important detail that could make a significant difference for people in that age range. I'm curious though - if someone turns 55 during the year (let's say in June), do they get the full $1,000 catch-up contribution for that year, or is it prorated based on the months they were 55? And does the last month rule apply differently to catch-up contributions compared to regular contributions? Also, for married couples where both spouses have HSAs and one is 55+, I assume each person gets their own catch-up contribution limit based on their individual age, not combined as a family unit?

0 coins

IRS AI

Expert Assistant
Secure

Powered by Claimyr AI

T
I
+
20,095 users helped today