Who must file Form 1099-SA
File Form 1099-SA if you are the trustee or custodian of an HSA, Archer MSA or Medicare Advantage MSA and you made a distribution during the year, including a distribution of excess contributions with earnings, a deemed distribution from a prohibited transaction or pledged account, and a distribution to a beneficiary or the estate after the account holder's death. A trustee-to-trustee transfer between like accounts is not reported. Contributions and year-end value go on Form 5498-SA, due May 31.
After death, a spouse beneficiary becomes the account holder and reports as such; a non-spouse beneficiary receives the FMV in box 4 with code 4 or 6, and the estate receives it under the estate's EIN.
Threshold: All amounts, every distribution from an HSA, Archer MSA or MA MSA; no minimum.
What is reported, box by box
| Box | What it reports | Notes |
|---|---|---|
| 1 | Gross distribution | Including amounts paid directly to a provider; do not include trustee-to-trustee transfers. |
| 2 | Earnings on excess contributions | When code 2 is used. |
| 3 | Distribution code | 1 normal; 2 excess contributions; 3 disability; 4 death (other than to a spouse in the year of death); 5 prohibited transaction; 6 death distribution after the year of death to a non-spouse. |
| 4 | FMV on date of death | For a distribution to a non-spouse beneficiary or estate. |
| 5 | HSA, Archer MSA or MA MSA | Checkbox for the account type. |
Box titles follow the current revision of the form. The IRS reads the payer and recipient name, TIN, address, account number and the money boxes; the state boxes are for the state copy only.
Payments that are not reported on Form 1099-SA
- Trustee-to-trustee transfers from one Archer MSA or HSA to another, and rollovers the trustee treats as transfers.
- A mistaken distribution the trustee allows the holder to repay (it may be treated as never distributed; the trustee is not required to allow it).
Due dates and extensions
| Copy | Due | For 2026 returns |
|---|---|---|
| To the IRS, paper | February 28 | Monday, March 1, 2027 (February 28 is a Sunday) |
| To the IRS, electronic | March 31 | Wednesday, March 31, 2027 |
| To the recipient | January 31 | Monday, February 1, 2027 (January 31 is a Sunday) |
An automatic 30-day extension is available on Form 8809, filed by the due date on paper or through IRIS; a second 30 days requires a hardship showing. Recipient statements can be extended 30 days on Form 15397, online or by fax only. 10 or more information returns of any type in aggregate must be e-filed (T.D. 9972); IRIS is the only IRS intake system from filing season 2027, FIRE having been retired. A payer who e-files the originals must e-file the corrections.
For 2026 forms filed in 2027: January 31 falls on a Sunday, so that deadline moves to Monday, February 1, 2027; February 28 also falls on a Sunday, so the paper deadline moves to Monday, March 1, 2027. March 31 (electronic) and March 15 are weekdays. February 28 does not become February 29 in a leap year. The compliance calendar has every date with the weekend shifts applied.
Withholding and TIN matching
HSA and MSA distributions are exempt from backup withholding and 1099-SA is not in the IRS TIN Matching program. The penalty is $50 per return under IRC 6693 with no maximum. Because most HSAs are opened through an employer's benefits enrollment, the name on the account is whatever HR's system carried; the trustee is the filer and owns the mismatch.
Name and TIN errors on this form
Every information return is matched by the IRS on the first four characters of the payee's name (the name control) against the TIN. For this form the penalty is IRC 6693: $50 per return for each failure to file or furnish, with no annual maximum, unless the failure was due to reasonable cause. A mismatch still produces a CP2100 line the following autumn. The errors that recur on Form 1099-SA:
- Employer-fed enrollment. Payroll files feed the HSA custodian names that may include nicknames or truncated surnames; the SSA record is the one that matters.
- Death distributions. Spouse: the spouse is the account holder going forward, reported under the spouse's SSN. Non-spouse beneficiary: their own SSN with code 4. Estate: the estate's EIN.
- Excess contribution returns report to the account holder with code 2 and earnings in box 2.
The name control calculator shows what the IRS will derive from a name line, and the CP2100 guide covers what to do when the notice arrives.
Recipient statements and substitutes
The recipient statement for Form 1099-SA need not be a copy of the official form: a substitute may be combined with other account statements or reports, provided every required item is numbered and titled as on the official form, the tax year, form number and form name appear together, the recipient instructions are included, and, for the forms Pub 1099 lists, a telephone number with direct access to someone who can answer questions is shown. Publication 1179 (Rev. Proc. 2026-18) has the specifications; logos, slogans and advertising are not permitted on the statement itself. Statements may be furnished electronically only to a recipient who has affirmatively consented in a way that shows they can access the format, after the disclosures in Pub 1099 part M, and must stay posted through October 15. Copy B may show a truncated TIN (xxx-xx-1234); the IRS copy never may.
Corrections and state copies
A wrong amount, code or checkbox is a Type 1 correction: one corrected return with the CORRECTED box checked. A wrong or missing payee TIN, a wrong payee name, or the wrong form type is a Type 2 correction: a zeroed-out copy of the original plus a new original, in that order. Publication 1099 also says you are not required to file a correction for a missing or incorrect TIN if you meet the reasonable-cause standard, only to use the right TIN on the next return, although the IRS encourages the correction. Details and the paper error charts are on the 1099 corrections page.
Form 1099-SA is not in the Combined Federal/State Filing program, so any state that requires it must receive it directly. Requirements by state are on the state pages.
Questions people ask about Form 1099-SA
Do we report a rollover from one HSA to another?
Not if it is a trustee-to-trustee transfer. A distribution the holder receives and re-deposits within 60 days is a distribution on 1099-SA and a rollover contribution on 5498-SA.
An account holder used the debit card for groceries.
Still a normal distribution, code 1; taxability is the holder's issue on Form 8889.
Is 1099-SA in the Combined Federal/State program?
No.
Other federal forms
1042-S · 1097-BTC · 1098 · 1098-C · 1098-E · 1098-F · 1098-Q · 1098-T · 1098-VLI · 1099-A · 1099-B · 1099-C · 1099-CAP · 1099-DIV · 1099-G · 1099-INT · 1099-K · 1099-LS · 1099-LTC · 1099-MISC · 1099-NEC · 1099-OID · 1099-PATR · 1099-Q · 1099-QA · 1099-R · 1099-S · 1099-SB · 3921 · 3922 · 5498 · 5498-ESA · 5498-SA · W-2G · 1099-DA · Comparison table
Sources: IRS Publication 1099 (2026), General Instructions for Certain Information Returns, which replaced the separate General Instructions starting with tax year 2026; Instructions for Forms 1099-SA and 5498-SA (Rev. December 2026); Pub 1099 (2026) part O; IRC 220(h), 223(h), 6693. Threshold amounts are indexed for inflation from calendar year 2027; check IRS.gov/InflationAdjustment for the current year.