Does an Employer Offering HDHP but Not Contributing to HSA Need to Charge FMV at Onsite Clinic?

Many employees wonder if their employer, who offers a High Deductible Health Plan (HDHP) but does not contribute to a Health Savings Account (HSA), should charge Fair Market Value (FMV) at the onsite clinic. The answer to this question depends on various factors.

When an employer provides an HDHP without contributing to the HSA:

  • Employees can still contribute to their HSA and enjoy tax benefits.
  • The employer's decision not to contribute does not impact the tax advantages of the HSA for employees.

As for the onsite clinic, it is essential to consider the following:

  • Charging FMV at the onsite clinic might be a common practice for employers to ensure fairness and compliance.
  • The decision to charge FMV can vary based on company policies and regulatory requirements.

In conclusion, while there is no strict rule mandating FMV charges at onsite clinics for employers who do not contribute to employees' HSAs, it is advisable to consult with legal and financial experts to make informed decisions.


Employees may be left wondering about their employer's decisions when it comes to High Deductible Health Plans (HDHP) and Health Savings Accounts (HSA). When an employer offers an HDHP without contributing to an HSA, it is important to note that employees can still make their own contributions, thereby unlocking significant tax benefits that come with the account.

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