Form 5498-SA: HSA, Archer MSA, or Medicare Advantage MSA Information
Reports contributions to Health Savings Accounts, Archer MSAs, and Medicare Advantage MSAs, including rollover contributions and fair market value.
Overview
IRS Form 5498-SA is an informational return filed by the trustee or custodian of a Health Savings Account (HSA), Archer Medical Savings Account (Archer MSA), or Medicare Advantage MSA (MA MSA). Its primary purpose is to report contributions made to these tax-advantaged healthcare accounts during the calendar year, along with the account's fair market value as of December 31. The form is submitted to both the IRS and the account holder, giving the IRS a mechanism to verify that contributions reported on individual returns — chiefly via Form 8889 for HSAs — are consistent with what trustees actually received.
The legal authority for HSAs sits in IRC Section 223, which defines contribution limits, eligible individuals, and the tax treatment of distributions. Archer MSAs are governed by IRC Section 220, an older regime that predates HSAs and is now largely closed to new participants. Medicare Advantage MSAs fall under IRC Section 138. All three account types share the common thread of allowing pre-tax dollars to fund qualified medical expenses, and Form 5498-SA is the reporting backbone that keeps contribution records straight across all three.
From a practical standpoint, Form 5498-SA is a trustee obligation — individual taxpayers do not file it. However, account holders should reconcile the amounts reported on their 5498-SA against what they claimed on Form 8889 (for HSAs) or their individual return (for Archer MSAs). Because the filing deadline of May 31 falls after the individual income tax deadline of April 15, the IRS explicitly permits HSA trustees to send account holders a preliminary statement by January 31 showing prior-year contributions, with the official 5498-SA following later. CPAs should remind clients to retain their 5498-SA for at least three years as documentation supporting the HSA deduction or exclusion claimed on their return.
Who Files This Form?
Form 5498-SA must be filed by any trustee or custodian that maintained an HSA, Archer MSA, or Medicare Advantage MSA on behalf of an individual during the tax year. This obligation is triggered by the existence of the account — even if no contributions were made during the year, a 5498-SA is still generally required to report the fair market value of the account as of December 31.
For HSAs, contributions that trigger reporting include: employee payroll contributions (which are excluded from gross income under IRC Section 223), self-employed or individually made contributions (which are deductible above-the-line), employer contributions (which are excluded from income and not deductible by the employee separately), and rollover or trustee-to-trustee transfer amounts. Note that trustee-to-trustee transfers between HSAs are not reported on 5498-SA, but rollover contributions — where the account holder takes a distribution and redeposits within 60 days — are reported in the rollover box.
For Archer MSAs, the rules are similar but the population of eligible filers is narrow: Archer MSAs were frozen to new participants after 2007 and only individuals already enrolled or eligible through a qualifying small employer health plan may contribute. Trustees of existing Archer MSA accounts still have a Form 5498-SA filing obligation each year for active accounts.
Medicare Advantage MSAs are funded exclusively by the Medicare program through the MA plan, not by the account holder. The MA plan or its administrator is responsible for reporting these contributions.
A key exception: direct transfers between HSA trustees (trustee-to-trustee transfers) do not need to be reported on Form 5498-SA, distinguishing them from rollovers. Trustees should also note that contributions made for the prior tax year but received between January 1 and April 15 (or the tax return due date including extensions) should be reported for the year to which they apply, not the year received.
Key Fields
Box 1: Employee or Self-Employed Person's HSA Contributions
Reports contributions made by the account holder — either through after-tax personal contributions or pre-tax payroll deferrals — to an HSA. This figure should match or reconcile with the amount the individual claims on Form 8889, Part I. A common gotcha: employer contributions made through a Section 125 cafeteria plan are sometimes misclassified here instead of Box 2.
Box 2: Total Contributions Made in [Year]
This is the aggregate of all contributions to the HSA for the tax year, including both employee/self-employed contributions and employer contributions. It represents the total that will be compared against the applicable annual contribution limit to determine whether an excess contribution exists. CPAs should verify this figure ties to the sum of Boxes 1 and 9.
Box 3: Total HSA or Archer MSA Contributions Made in [Year] for [Prior Year]
Reports contributions received between January 1 and April 15 (or the extended due date) of the current year but designated by the account holder as applying to the prior tax year. This box is critical for year-end tax planning — contributions made up to the filing deadline can still count toward the prior year's limit, and the trustee must track this designation carefully.
Box 4: Rollover Contributions
Captures HSA-to-HSA or Archer MSA-to-HSA rollover amounts where the account holder took a distribution and redeposited it within 60 days. Rollovers are not counted toward the annual contribution limit. Trustee-to-trustee transfers are excluded from this box entirely — only indirect rollovers appear here.
Box 5: Fair Market Value of HSA, Archer MSA, or MA MSA
The account's fair market value as of December 31 of the reporting year. This figure does not directly affect the account holder's current-year tax return but is used by the IRS to track account balances and can be relevant when calculating excess contribution penalties or evaluating account activity. For accounts holding non-publicly-traded assets (rare in practice), valuation methodology must be defensible.
Box 6: Account Type Checkbox
Indicates whether the account is an HSA, Archer MSA, or Medicare Advantage MSA. This checkbox drives how the IRS processes the form, since the three account types have different contribution rules and limits. Trustees must ensure the correct box is checked, particularly when an Archer MSA is being converted or rolled into an HSA.
Box 8: Employer Contributions
Reports contributions made directly by an employer to an employee's HSA outside of a Section 125 cafeteria plan, or through a cafeteria plan where the employer is the designated contributor. These amounts are excluded from the employee's gross income and wages and should not also appear in Box 1. If employer contributions appear in the employee's W-2 Box 12 Code W, they are also reflected here — CPAs should cross-check these figures.
Box 9: Archer MSA Contributions
Used specifically for Archer MSA accounts to report contributions made by the account holder or self-employed individual. Because Archer MSAs have their own contribution limits (tied to a percentage of the HDHP deductible), CPAs working with the small universe of remaining Archer MSA holders should verify these limits separately from HSA limits.
Filing Deadlines
May 31
Penalties range from $60 to $310 per form for late filing.
Step-by-Step Instructions
- 1
Gather all contribution records for each HSA, Archer MSA, or MA MSA account maintained during the tax year, including payroll contribution data from employers, direct contributions from account holders, and any rollover documentation.
- 2
Separate contributions by type: distinguish employee/self-employed contributions (Box 1), employer contributions (Box 8), prior-year contributions received in the current year (Box 3), and rollover amounts (Box 4). Do not double-count cafeteria plan contributions — these should appear in Box 8, not Box 1.
- 3
Determine the account's fair market value as of December 31 of the reporting year for Box 5. For standard cash and investment HSAs, this will be the custodian's year-end statement value. Document the valuation methodology for any non-standard assets.
- 4
Check the account type checkbox in Box 6 to confirm whether the account is an HSA, Archer MSA, or Medicare Advantage MSA. If an Archer MSA was rolled into an HSA during the year, confirm the correct reporting treatment for each account period.
- 5
Populate the total contributions in Box 2 and verify it equals the sum of reportable contributions (Boxes 1 and 8, adjusted for any prior-year designated amounts). Flag any totals that appear to exceed the applicable annual contribution limit, as this may indicate an excess contribution the account holder needs to address.
- 6
File Copy A of Form 5498-SA with the IRS by May 31 of the year following the tax year being reported. For the 2026 tax year, the deadline is May 31, 2027. If filing electronically (required for trustees filing 10 or more information returns), use the IRS FIRE system.
- 7
Furnish Copy B (the account holder statement) to the account holder by May 31 as well, or provide a substitute statement by January 31 showing estimated or actual prior-year contribution totals to assist account holders who are filing their returns before the official 5498-SA is issued.
- 8
Retain a copy of each filed 5498-SA and supporting documentation for at least four years from the due date of the return, consistent with IRS record-retention guidance for information returns.
- 9
If a correction is necessary after filing — for example, a contribution was returned as an excess contribution and the originally reported amount was overstated — file a corrected Form 5498-SA by checking the 'CORRECTED' box and refiling with the IRS and account holder promptly.
Common Mistakes to Avoid
Reporting trustee-to-trustee transfers as rollover contributions in Box 4.
Trustee-to-trustee transfers between HSA accounts are not reportable on Form 5498-SA at all. Only indirect rollovers (where the account holder receives a distribution and redeposits within 60 days) belong in Box 4. Confirm with the custodian whether the movement of funds was a direct transfer or an indirect rollover before populating Box 4.
Including employer cafeteria plan contributions in Box 1 instead of Box 8.
Contributions routed through a Section 125 cafeteria plan are employer contributions and belong in Box 8. Placing them in Box 1 can cause the account holder's Form 8889 reconciliation to fail and may trigger unnecessary IRS notices. Cross-reference the employer's W-2 Box 12 Code W amounts to verify the split.
Failing to report a Form 5498-SA for accounts with no contributions but a positive year-end balance.
The filing obligation exists as long as the account was open and had a fair market value at year-end, even if no contributions were made. File the form with Box 5 populated and contribution boxes left blank rather than skipping the form entirely.
Misapplying the year for prior-year contributions made between January 1 and the tax deadline.
Contributions made in early 2027 and designated by the account holder for the 2026 tax year must be reported on the 2026 Form 5498-SA in Box 3, not on the 2027 form. Trustees need a documented process for capturing the account holder's designation at the time of contribution.
Missing the May 31 filing deadline because it is confused with the earlier April 15 individual return deadline.
Form 5498-SA has a statutory filing deadline of May 31, which is intentionally later than the individual return due date. Build this deadline into the firm's or trustee's compliance calendar separately from W-2 and 1099 deadlines. Penalties for late filing range from $60 to $310 per form depending on how late the filing is.
Overlooking the need to issue a corrected 5498-SA after an excess contribution is returned.
When an account holder withdraws an excess HSA contribution (with attributable earnings) before the tax deadline, the original contribution figures reported may need to be corrected downward. File a corrected Form 5498-SA promptly and notify the account holder so they can amend Form 8889 if already filed.
Frequently Asked Questions
You personally do not file Form 5498-SA — that is the responsibility of your HSA trustee or custodian. However, your trustee is still generally required to file the form even if no contributions were made, because the form must report the account's fair market value as of December 31. You should receive a copy from your trustee by May 31 regardless of contribution activity.
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