IRS Compliance

HSA Catch-Up Contributions For Married Couples

When both spouses have HSAs, the family limit is shared and each spouse who is 55 or older can add a catch-up. Here are the rules employers hear questions about.

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Family Coverage

One Family Plan Covers Both Spouses

Both Treated As Family

If either spouse has family HDHP coverage, both spouses are treated as having family coverage. This can surprise couples where one spouse has family coverage and the other has self-only coverage at a different employer. Employees should check both plans before contributing, and a tax adviser can confirm how the rule applies to them.

The Limit Is Split

The family limit is divided equally between the spouses unless they agree on a different split, after reducing for any Archer MSA contributions. Couples can choose a different split by agreement, but the combined total still cannot exceed the family limit. Remind employees that employer contributions count toward the total, and that excess contributions can create tax consequences.

Both Must Be Eligible

These rules apply only when both spouses are eligible individuals. If one spouse is not eligible, for example because of other disqualifying coverage, the rules may work differently. Employees in that situation should speak with a tax adviser rather than assume the standard split applies to them.

Catch-Up

Each Spouse Gets Their Own Catch-Up

Age 55 And Over

Each spouse who is 55 or older and not enrolled in Medicare may make a catch-up contribution. The catch-up is in addition to the regular limit, and it depends on each person’s own age and Medicare status. Encourage employees to confirm eligibility with a tax adviser, since the details can change from year to year.

Separate HSAs Required

The catch-up must go into the HSA of the spouse who qualifies. A spouse cannot make the other spouse’s catch-up contribution. Couples who both qualify for a catch-up each need their own account to receive it, even when one spouse carries the family coverage. Employers can mention this in enrollment materials so employees do not set up contributions incorrectly. For owner-specific rules, see HSA Rules for Business Owners.

Limits Change Yearly

We do not list dollar limits here because the IRS adjusts them each year. See the current IRS figures. Employers should direct employees to the IRS for the current numbers each year and update enrollment materials when the new figures are released. Avoiding printed dollar amounts keeps communications accurate and reduces the need for corrections.

Employer Role

What Employers Should Do

Employee Education

Explain that the split is the employee’s decision, and that employer contributions count toward the limit. Employees should also be told to track combined contributions across employers and accounts. Plain examples in enrollment materials help couples plan, and a reminder to consult a tax adviser keeps the employer from giving tax advice.

Payroll Elections

Allow employees to update contributions during the year where your plan permits. Employers should confirm with payroll how often changes can be made and how quickly they take effect. Employees who are close to the limit benefit from a reminder to review their elections before the end of the year.

Medicare Timing

A spouse who enrolls in Medicare can no longer contribute. See our Medicare and HSA guidance. Employees approaching Medicare eligibility should plan contributions around that date and ask a tax adviser how the timing works. HR can help by reminding employees to notify the plan when their coverage changes and by updating payroll promptly.

What The Statute Says

How Catch-Up Contributions Work For Married Couples

Age 55 Threshold

The additional catch-up amount is available to an eligible individual who has reached age 55 by the end of the tax year. Employees who are near this age can plan ahead for an additional contribution, though the exact rules should be confirmed with a tax adviser. Employers can mention the opportunity in enrollment materials without giving individual tax advice.

Each Spouse Needs Their Own Account

The catch-up applies to the individual, so a spouse who is 55 or older makes the catch-up contribution to an HSA in their own name. Employers should make sure payroll can direct each spouse’s catch-up to the correct account when both work for the company. A short worksheet or FAQ helps couples keep track of which account receives which contribution.

Family Limit Is Shared

For married individuals with family coverage, the annual limit is divided equally between spouses unless they agree on a different split. Because employer contributions count toward the same family total, couples should add up everything before choosing a split. Employers can include a simple example in enrollment materials and encourage employees to ask a tax adviser about their situation.

Both Spouses Must Be Eligible

Only an eligible individual can contribute. An eligible individual is covered by a high deductible health plan and generally not enrolled in Medicare. Employees who are enrolled in Medicare or covered by other disqualifying coverage cannot contribute, even if their spouse can. Employers should encourage workers to review their coverage and consult a tax adviser if the facts are unclear.

Medicare Changes Eligibility

Once an individual is enrolled in Medicare, contributions to that person’s HSA stop. A younger spouse can still contribute if they remain eligible. Employees should expect the change to affect how they plan contributions and should talk with a tax adviser before and after they enroll. Employers can remind staff to tell HR when coverage changes so payroll stays accurate.

Qualified Expenses Follow Section 213(d)

Tax-free withdrawals must be for qualified medical expenses as defined by reference to section 213(d) of the Internal Revenue Code. Employees should keep receipts and records in case of questions later, because they are responsible for using the funds for qualifying expenses. Employers can point staff to the IRS materials and suggest a tax adviser for specific questions.

Source: 26 U.S.C. 223.

Common Questions

Frequently Asked Questions

Do both spouses get a catch-up?

Yes, if each is 55 or older, eligible and not enrolled in Medicare.

Can one spouse put both catch-ups in their HSA?

No. Each catch-up must go into the HSA of the spouse who qualifies.

How is the family limit divided?

Equally, unless the spouses agree to a different split.

Do employer contributions count?

Yes, they count toward the limit.

Where are the dollar limits?

They change yearly. Check current IRS figures.

Is this legal advice?

No. This page is general information, not legal or tax advice. Rules change, so confirm current status with your attorney, tax advisor or the IRS.

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Sources

Laws and rules referenced

26 U.S.C. § 223 — Health savings accounts: eligibility, contribution limits and the age 55 catch-up.

Rev. Proc. 2025-19 and Rev. Proc. 2026-24 — Inflation-adjusted HSA and high-deductible health plan amounts for 2026 and 2027.

IRS Notice 2004-50 — HSA questions and answers: eligibility, other coverage, FSAs and HRAs, and contribution rules.

This page is general information, not legal or tax advice. Rules change and facts matter, so confirm your situation with counsel or a qualified advisor.

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