The HSA-as-IRA strategy isn’t a loophole. It’s an intentional design.
Here’s how it actually works:
1. Contribute the max ($4,300 individual / $8,550 family in 2025)
2. Invest the full balance—most custodians let you invest once you hit $1,000
3. Pay every medical expense out of pocket and keep the receipt
4. Let the account compound untouched for as long as possible
5. Reimburse yourself later—years or decades later—for the documented expenses
At 65, the HSA behaves like a traditional IRA for non-medical expenses: ordinary income tax on withdrawals, no penalty.
For medical expenses at any age: tax-free.
The receipt step is non-negotiable. That’s what makes the future withdrawal defensible.