How do other financial institutions handling Health Savings Accounts and dormancy? Do your HSAs go into dormancy? If so, what criteria do you use for them being transferred to dormancy? I'm performing a dormancy audit, and I can't find any regulations requiring HSA dormancy, but want to make sure I'm using best practices. Thanks in advance.

I'd like to hear something on this as well. we lengthened our HSA dormancy to 18 months. This has seemed to help.

An HSA is a deposit account. I would think they would be considered abandoned property after the appropriate amount of time has passed, as any other deposit account. State law governs abandoned property.

In Michigan HSAs are considered tangible property. So custodial funds established under a plan to provide health are escheatable in the State of Michigan.