HSA Primary Depository Transition
January 25, 2022 | HSA
Frequently Asked Questions
Primary Depository Transition for ACH Processing
On March 31, 2022, BMO Harris will become the primary depository for your employees’ HSAs. In its role as primary depository, BMO Harris will become the new ACH origination provider, handling all money movement to and from your employee’s HSAs, including contributions to and payments from those accounts. We are working with our HSA administration partner to ensure this is a smooth transition.
What is changing as part of this transition?
You can expect the following changes as part of this transition:
- New routing number: Employer contributions using WealthCare Administration (WCA)
- New routing number: Unsolicited ACH, e.g. direct deposit/debit from your employees’ accounts.
- Company IDs used for ACH transactions
- ACH filters for payroll contributions
- Wiring Instructions
What types of money movement are affected?
Money movement impacts include:
- Your contributions via ACH and/or wire transfers will now move through depository accounts established with BMO Harris.
- Individual contributions and provider payments will be done using new BMO Harris account information.
- Contributions made via check will not be impacted by this transition.
Who does this change affect?
This change affects:
- Employers that offer HSAs and contribute either pre-tax employee and/or employer contributions to their employee HSAs via ACH filter
- Employees who make contributions to their HSA via an ACH direct deposit from a personal bank account or provider initiated payments via ACH debit directly from their HSA. For example: account holder has provided provider with HSA bank account information for payment processing.
How do I know if my bank uses ACH filters?
If you’re unsure if your bank uses ACH filters, please check with your finance team.
Will there be any change to what I see within the benefits platform after this transition?
No. When you view existing plans or accounts within the benefits platform, you will see the same account type code you do today. Note: On the member portal, the account type code is not displayed.
What is the timeline for these changes?
These changes will take effect March 31, 2022. If you use ACH filters, we strongly urge you to add the new ACH filter prior to our next wave of testing beginning February 14, 2022. This will allow us to effectively conduct testing and ensure everything is working properly prior to the March 31, 2022 cutover date. Failure to complete this action may result in failed contributions after March 31, 2022.
We encourage you to communicate with employees who have automated bill payments via ACH direct debit or who make HSA contributions via ACH direct deposit. These employees will need to change the unsolicited ACH routing number. We will provide an email template that includes the new ACH routing number for you to send to your employees.
How will I keep informed about this change?
We will communicate with you during the ACH filter testing process, in advance of the custodian notification to employees who have previously initiated an unsolicited ACH credit or debit transaction, and after the cutover is complete.
What is expected of me as an employer in preparation for this cutover?
The following actions need to be taken based on how you contribute to your members HSA’s:
Funding Method | Definition | Employer Action | Testing |
ACH Pull | Funds are pulled from employer bank account based on contribution manager submission or invoice | Add new BMO Harris filters prior to February 14, 2022 | Week of 14-Feb and 14-Mar |
ACH Push | Funds are submitted from the employers account to individual’s HSA bank accounts | Add new BMO Harris filters Contributions on or after March 31, 2022 must go to BMO Harris. | No testing available |
Wire | Employer receives an invoice for contributions and wires funds accordingly. Note: Wire funding use is limited and based on group size | Add new BMO Harris payee Wires on and after March 31, 2022 must go to BMO Harris. | No testing available |
If you use ACH filters, please make the necessary changes to your company IDs and/or ACH filters with your respective banks before the March 31, 2022 cutover date. We will provide an implementaiton document that includes the new IDs and filters.
If you do not update the ACH filters, attempts to submit contributions could result in an ACH return. Per most contracts, there is a fee incurred for ACH returns.
Note: If you are processing a payroll contribution file before 3/31/22 with an effective date of 3/31/22 or AFTER please use the new BMO Harris banking filters.
How will my employees be notified?
WealthCare Saver will send a communication in 2022, prior to the March 31, 2022 cutover, to employees who have previously initiated an unsolicited ACH credit or debit transaction. However, we recommend you also notify your employees mid-March using the email template provided.
What is expected of the employee prior to the change?
If employees make direct deposits to their HSA or have automatic bill pay set up with their medical provider to pull funds from their HSA, they must change the routing number with their banking institutions and/or medical providers effective March 31, 2022. We will provide an email template that includes the new IDs and filters for you to send to your employees.
If employees fail to update the routing number, the direct deposit or debit payment after March 31, 2022 may fail and the funds would be returned to the originating bank account. The employee would still be responsible for making that payment as agreed to with the provider.
Will there be any change to employees’ HSA account numbers as part of this transition?
No, employee HSA account numbers are not changing.
How will this depository change impact tax filing for 2022?
There will be no impact to 2022 tax filing as a result of this depository change. Employees will receive a 2021 Tax Form from the WealthCare Saver custodian.
Will members have new terms and conditions/disclosures?
There is no change to terms and conditions as part of this change.
Will this impact members investments?
There is no change to investments as part of this change