Answer:
The IRS is silent on this issue. It would be up to the HSA account holder to be able to prove that all withdrawals were for qualified expenses. The problem that most banks have is if the HSA is in a savings account, you face the six transactions a month limit problem. The other issue to consider is that if the customer withdraws HSA funds before the debit card transaction hits, you cannot overdraw a HSA account.
First published on BankersOnline.com 4/14/08