Qualifying for a subsidy can make your clients ineligible for an HSA plan

Did you know that qualifying for a subsidy on the exchange can make your client ineligible for an HSA plan?
Here’s what happens
When a client buys a Health Savings Account (HSA) plan, federal law requires that health plan to have a deductible of at least $1,250 per individual and $2,500 per family to be paired with an HSA.
When your clients select a Silver level HSA plan on the exchange, they follow appropriate steps to determine if they are eligible for a subsidy.  If they do not qualify for a subsidy, they get the Silver HSA plan selected. If they do qualify for a subsidy, they might not be eligible for the Silver HSA plan they wanted.
Here's why it happens
Premium subsidies actually decrease the deductible and out-of-pocket costs.  Sometimes a subsidy can decrease these amounts enough to drop them below the federal government's minimum deductible threshold for HSA eligibility.  And if that happens, your client would become ineligible for the HSA feature but automatically enrolled in the base plan without the HSA component. Unfortunately at this time, there’s no messaging on the exchange to tell your clients this is happening.
If this happens to your client
Consider these options if this happens to your client:

• If they want to keep the plan they have, along with their subsidy, they don’t need to do anything. They won’t have the HSA feature, but they will have a lower-cost health plan, due to the subsidy assistance.
• If they want to switch to a plan with an HSA, they can do so during the next open enrollment period, October 15 through December 15, 2014. They'll get more information on this in the fall. But changing to a plan with the HSA feature means giving up their premium subsidy, which also means their coverage will cost more.