I do not believe they “inherit” the “accounting”, because the accounting (qualified medical expense on date of service) exists independent of the account owner. Therefore, here is why I believe you can make qualified distributions for such qualified medical expenses. There is no explicit guidance on this and many other issues resulting from the death of the HSA account owner. As is often the case you must infer the treatment from other relevant treatments.

• An HSA account owner can reimburse their, their spouse’s and their dependent’s unreimbursed qualified medical expenses with dates of service after the establishment date of their first HSA account.
• The status as a spouse or a dependent is determined on the date of service not the date of distribution. For example, an HSA account owner could reimburse for qualified medical expenses of their spouse after the death of that spouse and their dependent after that individual is no longer a dependent or has died.
• A spouse beneficiary is treated as if the inherited HSA account is now their HSA account. Therefore, the spouse can reimburse any qualified medical expense of their deceased spouse because the distribution options are the same as any other HSA account they would own.

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