Is the HSA a Health or a Retirement Savings Benefit?

Panelists at the PLANADVISER/PLANSPONSOR HSA Conference discussed how to position the HSA to get the most out of the benefit for employees.


Health savings accounts are growing in use and popularity as an employee benefit. With advantages both in health care spending and long-term retirement savings, employers can present the benefit in multiple ways.

Panelists at PLANADVISER/PLANSPONSOR 2023 HSA Conference said it can be used as both a health care and a savings benefit, but that will often depend on an employee’s wealth situation.

“Is it a health care or retirement savings benefit? My response to that is that it’s a ‘Yes, and.’ It’s not an ‘Either, or’—this is a product that spans both [benefit areas],” said Karen Coomber, vice president of intermediary business development at Fidelity Health Solutions.

Coomber added that Fidelity publishes an annual report on what an average couple retiring today should expect to spend on health care costs during retirement, with the most recent number hitting $315,000. “There’s certainly a need that we think HSAs can help address, both now and later, and there’s a real opportunity to position them as part of people’s financial picture,” she said.

Danovan Clacken, director of health and benefit account distribution, east at Bank of America, told the conference that how an HSA is used will largely depend an employee’s financial situation.

“There are going to be some employees that have to use that money today and will immediately look at it as a health care benefit,” Clacken said. “There are some individuals who will position it more as a longer-term retirement vehicle where they don’t necessarily need to spend that money today, and it can be a kind of 401(k) for health care.” 

Hurdles to Uptake

HSAs have been around since 2004, but despite that 20-year existence, many employees still do not fully understand them or their value, according to the panel.

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According to employers, many of their employees “aren’t really taking advantage of the account[s] the way they were written or intended,” Coomber of Fidelity said, noting a Fidelity survey that showed while 80% of employers surveyed were offering an HSA, only 40% of that same employee pool reported using the HSA. “I do think sometimes they are getting lost in the shuffle of benefits.”

On the plus side, Coomber said 72% of Millennials say they like to see an HSA being offered with a new job. As this younger cohort is more aware of HSAs, that presents an opportunity for employers “to highlight their commitment to making health care more affordable and helping people in all income brackets put aside some money and help it to grow.”

Among employers not offering an HSA, some avoid offering it because they think it is only for highly compensated employees, according to Jon Fortune, director ofworkplace product and solutions at Transamerica. Fortune said it is important to educate employers, since 78% of HSA accounts are held by people with less than $100,000 in annual income.

“It’s so important for them making those incremental gains toward financial independence, toward covering the unexpected, and they can do that through their HSAs,” he said.

Another factor limiting employers’ communication opportunities can be busyness, panelists said, given other priorities such as recruiting, retention and enrollment season. One way to get around that is for benefit providers to discuss the HSA “off-cycle,” or mid-year, so it ’i not in conjunction with the busy annual enrollment period, Fortune suggested.

The Right Fit

 From an employer perspective, a key to HSA growth is to find the right provider that can meet specific needs and consider the employee pool, according to the panelists.

“Employers should be looking for a partner, not a vendor,” Clacken of Bank of America said. “We don’t want to look at this as a transactional experience.” Clacken said employees should be asking their HSA provider: “‘How are you going to help my employees pay for what is the second-highest cost in retirement? How are you going to help communicate this to my employees?’”

Plans can be personalized to offer different types of HSAs or to deliver the best communication and education for their specific employee pool, Clacken said. In that way, the provider can be as much of a consultant as a vendor.

Greg Puig, vice president of benefit consulting services at Sentinel Group, told the group that he focuses on five areas when helping clients in choosing an HSA partner. Those include: 1) the ability the HSA provider has from a spending perspective, such as offering a debit card; 2) the savings aspects in terms of the investment lineup; 3) what is their application or tech stack for users?; 4) are they integrated with the employer’s payroll vendor?; and 5) what are their participant services in terms of employees getting personalized customer service?

Overall, communication to employees is key for the success of an HSA, Puig said. That education should happen both in, and out of open enrollment periods so it’s not all done in one moment.

“You need to really be able to go deeper into what the HSA can provide for employees,” Puig said, noting that an employer has to be able to create a communication strategy that reaches all types of users, no matter their income level or age.

“We have a lot of different generations in the workforce right now, so it has to be an array of ways in which you reach people in your employee base,” Puig said. “We have to remember how the participant thinks and what they may be feeling if this is the first time they are being presented [with] this type of plan.”

Execution Quality Disclosure, Tick-Size SEC Proposals Enjoy Industry Support

Mandatory auctions and Reg BE are considerably less popular.


Now that the Securities and Exchange Commission has closed the comment period for the four market structure proposals and as industry participants continue to comment on them in public venues, something of a consensus on the four would-be rules is emerging.

Rule 605 of Reg NMS

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By far the most popular of the four proposals is the update to Rule 605 of Regulation National Market System. This proposal would require larger broker/dealers to file monthly quality-of-execution reports; increase the number of executions required to be accounted for in these reports (such as orders placed outside normal business hours); and require new statistical measures to be included. Covered entities would also have to make a summary report available to the public.

Many in the industry have advocated for a sequenced implementation of the rules, assuming more than one is finalized. These sequencing proposals typically suggest that the Rule 605 update come first, in part because it is the most popular, and also because having solid disclosure rules in place would make it easier to assess the effectiveness of the other rules as they come online.

Debbie Toennnies, head of regulatory affairs at JPMorgan Chase’s corporate and investment bank, said this week at a roundtable hosted by the Securities Industry and Financial Markets Association, that the proposals should be implemented one at a time so that if one ends up doing more harm than good, it will be easier to identify which is causing the problems. Issuing Rule 605 first would provide more data to help make this assessment, she said.

There have been some misgivings expressed regarding the Rule 605 update, however.

Terrence Hendershott, a professor at the Haas School of Business at the University of California, Berkeley and a former chair of the Nasdaq Economic Advisory Board, noted that measuring execution quality for trades that are cancelled would be difficult and it might skew or misrepresent the quality of the data produced for brokers who have more cancelled orders than average.

Gregg Berman, managing director for market analytics and regulatory structure at Citadel Securities, said he was nervous about a single summary report across all stocks and orders and wanted more specifics from the SEC. He said no consumer wants to know the average price of all products at a store, because that information would not be actionable and could lead to bad decision making by compressing data.

Both of these points were framed in terms of what could be improved in the proposal and were not calls to retract it.

Tick Sizes

The second proposal that has found widespread support in the industry is the SEC’s proposal to reduce tick sizes for certain tick-constrained stocks. Nasdaq expressed support for the proposal in its comment letter to the SEC and recommends permitting half-penny ($.005), increments (Nasdaq also supported Rule 605).

Joseph Mecane, head of execution services at Citadel Securities, remarked at the SIFMA roundtable that the SEC should adopt the Rule 605 reform and tick sizes and scrap the other two proposals. This sentiment was shared by Michael Blaugrund, the chief operating officer of the New York Stock Exchange, who cited a joint comment letter signed by Charles Schwab and Citadel Securities.

Reg BE

The other two proposals, which the industry has opposed, address trade execution and securities auctions.

The first proposal would take Regulation Best Execution, currently enforced by the Financial Industry Regulatory Authority, and put it under SEC jurisdiction. Nick Losurdo, a partner in law firm Goodwin, commented that there is “broad consensus that Reg BE is not needed.” Others at the roundtable said that FINRA’s enforcement is clear and already understood, including Dan Gallagher, the chief legal compliance and corporate affairs officer at Robinhood.

Auctions

The tone for the last proposal, requiring short auctions for certain segmented orders, was more gloomy.  The order competition rule, or auction proposal, would require auctions of between 100 and 300 milliseconds for certain segmented retail orders.

Gallagher said that the Reg BE and auction proposals, are “not serious” and are “not right for a serious agency,” referring to the SEC, while Jessica Wachter, SEC’s chief economist and the director of the SEC’s Division of Economic Risk and Analysis was in attendance at the SIFMA roundtable.

Berman said of Reg BE and auctions that he does not know “how you could comply with both at the same time.” The time required to execute an auction could lead to a price change that is disfavorable to the client, which would cut against Reg BE, but if they send orders to other venues to get a better price, they might be violating the auction requirement.

Christopher Larkin, managing director and head of investing and trading at Morgan Stanley’s E-Trade, noted that there would be a large technical and administrative burden for “untested” auctions. The auctions could lead to negative consequences due to market changes during the course of the auction. Berman expanded on this point and said that, currently, orders are handled sequentially. Under the auction proposal, many auctions would take place simultaneously for the same securities from different market participants. This could lead to those who placed their orders first being priced out by subsequent offers and not getting the price they thought they would get, which could cause a failed auction and a bad customer experience.

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