I
119THCONGRESS
1
STSESSION H. R. 2667
To amend the Internal Revenue Code of 1986 to allow distributions from
a health flexible spending arrangement or health reimbursement arrange-
ment directly to a health savings account in connection with establishing
coverage under a high deductible health plan.
IN THE HOUSE OF REPRESENTATIVES
APRIL7, 2025
Mr. B
EANof Florida (for himself, Mr. PANETTA, and Mr. CRENSHAW) intro-
duced the following bill; which was referred to the Committee on Ways
and Means
A BILL
To amend the Internal Revenue Code of 1986 to allow dis-
tributions from a health flexible spending arrangement
or health reimbursement arrangement directly to a health
savings account in connection with establishing coverage
under a high deductible health plan.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Flexible Savings Ar-4
rangements for a Healthy Robust America Act’’. 5
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SEC. 2. FSA AND HRA TERMINATIONS OR CONVERSIONS TO 1
FUND HSAs. 2
(a) I
NGENERAL.—Section 106(e)(2) of the Internal 3
Revenue Code of 1986 is amended to read as follows: 4
‘‘(2) Q
UALIFIED HSA DISTRIBUTION .—For pur-5
poses of this subsection— 6
‘‘(A) I
N GENERAL.—The term ‘qualified 7
HSA distribution’ means, with respect to any 8
employee, a distribution from a health flexible 9
spending arrangement or health reimbursement 10
arrangement of such employee directly to a 11
health savings account of such employee if— 12
‘‘(i) such distribution is made in con-13
nection with such employee establishing 14
coverage under a high deductible health 15
plan (as defined in section 223(c)(2)) after 16
a significant period of not having such cov-17
erage, and 18
‘‘(ii) such arrangement is described in 19
section 223(c)(1)(B)(iii) with respect to 20
the portion of the plan year after such dis-21
tribution is made. 22
‘‘(B) D
OLLAR LIMITATION.—The aggre-23
gate amount of distributions from health flexi-24
ble spending arrangements and health reim-25
bursement arrangements of any employee which 26
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may be treated as qualified HSA distributions 1
in connection with an establishment of coverage 2
described in subparagraph (A)(i) shall not ex-3
ceed the dollar amount in effect under section 4
125(i)(1) (twice such amount in the case of cov-5
erage which is described in section 6
223(b)(2)(B)).’’. 7
(b) P
ARTIALREDUCTION OF LIMITATION ONDE-8
DUCTIBLEHSA CONTRIBUTIONS.—Section 223(b)(4) of 9
such Code is amended by striking ‘‘and’’ at the end of 10
subparagraph (B), by striking the period at the end of 11
subparagraph (C) and inserting ‘‘, and’’, and by inserting 12
after subparagraph (C) the following new subparagraph: 13
‘‘(D) so much of any qualified HSA dis-14
tribution (as defined in section 106(e)(2)) made 15
to a health savings account of such individual 16
during the taxable year as does not exceed the 17
aggregate increases in the balance of the ar-18
rangement from which such distribution is 19
made which occur during the portion of the 20
plan year which precedes such distribution 21
(other than any balance carried over to such 22
plan year and determined without regard to any 23
decrease in such balance during such portion of 24
the plan year).’’. 25
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(c) CONVERSION TO HSA-COMPATIBLEARRANGE-1
MENT FOR REMAINDER OF PLANYEAR.—Section 2
223(c)(1)(B)(iii) of such Code is amended to read as fol-3
lows: 4
‘‘(iii) coverage under a health flexible 5
spending arrangement or health reimburse-6
ment arrangement for the portion of the 7
plan year after a qualified HSA distribu-8
tion (as defined in section 106(e)(2) deter-9
mined without regard to subparagraph 10
(A)(ii) thereof) is made, if the terms of 11
such arrangement which apply for such 12
portion of the plan year are such that, if 13
such terms applied for the entire plan 14
year, then such arrangement would not be 15
taken into account under subparagraph 16
(A)(ii) of this paragraph for such plan 17
year.’’. 18
(d) I
NCLUSION OFQUALIFIEDHSA DISTRIBUTIONS 19
ONW–2.— 20
(1) I
N GENERAL.—Section 6051(a) of such 21
Code is amended by striking ‘‘and’’ at the end of 22
paragraph (16), by striking the period at the end of 23
paragraph (17) and inserting ‘‘, and’’, and by insert-24
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ing after paragraph (17) the following new para-1
graph: 2
‘‘(18) the amount of any qualified HSA dis-3
tribution (as defined in section 106(e)(2)) with re-4
spect to such employee.’’. 5
(2) C
ONFORMING AMENDMENT .—Section 6
6051(a)(12) of such Code is amended by inserting 7
‘‘(other than any qualified HSA distribution, as de-8
fined in section 106(e)(2))’’ before the comma at the 9
end. 10
(e) E
FFECTIVEDATE.—The amendments made by 11
this section shall apply to distributions made after Decem-12
ber 31, 2025, in taxable years ending after such date. 13
Æ
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