This study is 4 years old but I'm sure much has not changed since then. And it is a must read to help challenge those that argue in support.
GAO STUDY CONFIRMS HEALTH SAVINGS ACCOUNTS PRIMARILY BENEFIT HIGH-INCOME INDIVIDUALS <-links to the PDF document
SummaryA groundbreaking new study by the Government Accountability Office (GAO) demonstrates that Health Savings Accounts (HSAs) tax-favored savings accounts attached to high-deductible health insurance plans established under the 2003 Medicare drug law are heavily skewed toward affluent individuals. The GAO findings also provide strong indications that HSAs are being used extensively as tax shelters. Finally, the GAO data suggest that HSAs can be beneficial to healthy individuals with relatively few health care costs, but not to people who have medical conditions and incur higher costs.
Many health and tax policy analysts have warned in recent years that HSAs are likely to be used extensively as tax shelters by high-income individuals. The Administration and other HSA proponents have rejected such concerns and argued that HSAs are not disproportionately used by high-income households.
Until recently, though, little or no solid data have been available to assess whether HSAs are or are not being used disproportionately by affluent individuals. The primary data available have been on enrollment in HSA-eligible high-deductible plans in the small, individual health insurance market, which is skewed toward people at low and moderate income levels who cannot get employer-based coverage. Such data shed little light on HSA use in employer-based insurance,
where the vast bulk of Americans obtain their coverage.1 Moreover, such data do not appropriately distinguish between individuals enrolled in a HSA-eligible plan who are merely qualified to establish a HSA and the more limited number of individuals who have actually opened and are using HSAs.
Now, this has changed. An important GAO study issued earlier this month breaks new ground, by providing data from the Internal Revenue Service on who actually is using HSAs. The IRS data cover all Americans who made HSA contributions in 2004, regardless of whether they had individual or employer-based coverage.4 The GAO study also contains data, from three large employers who offer both HSA-eligible plans and traditional coverage, on how their employees have sorted themselves between HSA-eligible coverage and traditional insurance.
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The principal findings in the GAO report include the following.
The Income of HSA Participants
51 percent of tax filers making HSA contributions in tax year 2004 (the first year HSAs were available) had adjusted gross income of $75,000 or more. This represents a decisive skewing toward higher-income individuals, since only 18 percent of all tax filers under age 65 had incomes of $75,000 or more in 2004.
The average adjusted gross income of tax filers reporting HSA contributions in 2004 was $133,000, as compared to $51,000 for all tax filers under age 65 in 2004.
In addition to making much greater use of HSAs, higher-income individuals also make larger tax-deductible contributions to HSAs. HSA participants who had incomes over $200,000 contributed an average of $3,010 in 2004. This was more than double the average contribution of $1,370 for HSA participants who had incomes below $50,000. This difference in average contribution levels further skews the tax benefits of HSAs to households that are high on the income scale.
The Income of HSA Participants
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Indications of Use of HSAs as a Tax Shelter
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HSAs and High Deductible Plans Reduce Costs for the Healthy, But Raise Them for the Less Healthy
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ConclusionHealth and tax policy analysts long have warned that HSAs could be used extensively as tax shelters by high-income individuals. They have also expressed concerns that HSAs would be disproportionately attractive to healthier individuals and risk adverse selection. The GAOs analysis of the IRS data, as well as its case studies of three large employers, lend strong credence to these concerns.
In its concluding observations, the GAO warns that when individuals are given a choice between HSA-eligible and traditional plans as in the individual market and with employers offering multiple health plans HSA-eligible plans may attract healthier individuals who use less health care or, as we found, higher-income individuals with the means to pay higher deductibles and the desire to accrue tax-free savings.
The GAO has thus effectively added its voice to the voices of health policy experts who have warned that HSAs may result in adverse selection, with healthier and less-healthy people separating into different insurance arrangements. If adverse selection becomes widespread, it is likely to pose serious risks to those Americans who are in poorer-than-average health, since the higher health care costs they must incur will no longer be pooled with the lower costs of individuals who are healthy. An increase in the number of Americans with below-average health who are uninsured or underinsured or who receive adequate health insurance only by failing to meet other basic needs would not be a desirable outcome for the nation.