To encourage individuals to avoid hospitals when appropriate during the COVID-19 health crises, Congress passed relief permitting coverage for telehealth services before satisfying the deductible of the HDHP while maintaining HSA eligibility. This relief is set to expire with plan years beginning in 2025.
Normally a telehealth plan (whether stand-alone or built into a group health plan) is disqualifying coverage and causes a loss of HSA eligibility unless the telehealth plan has a deductible or charges fair market value (FMV) each time participants use the service until the minimum deductible required for a qualifying HDHP is met. Therefore, unless congressional action occurs, beginning in 2025, offering a telehealth option that provides more than preventive care with no cost to participants will result in ineligibility to make or receive HSA contributions.
Potential Congressional Solutions
There appears to be bipartisan support for extending this relief beyond 2024 plan years, but it isn’t clear what this relief may look like or whether Congress will be successful in including it in end of year legislation. However, with the upcoming election and the expiration date for the relief fast approaching, this seems unlikely. It is perhaps more likely that another temporary relief extension will be included in end of the year budget legislation.
Related Blogs
Pharmacy
PUBLISHED
August 26th, 2025
WHAT LOOKS LIKE A PHARMACY BENEFIT SOMETIMES ISN’T: THE J-CODE CONUNDRUM
Chris Antypas
From what I’ve seen, more than three quarters of employers are facing at least one J-code issue. And because medically administered and infused drugs ...
Read More
Compliance
PUBLISHED
August 21st, 2025
Keeping Up with Compliance Quarterly—Q3 2025
DeAnn Deck
Keeping up with compliance developments can be difficult and time-consuming. This quarterly update highlights recent legal developments to help your organization stay on top ...
Read More
Benefits+
PUBLISHED
August 14th, 2025
Small Changes, Big Impact: Low-Cost Ways to Support Employees through Inflation
Julie Bingham
As inflation headlines re-emerge, many employers are contemplating shifts in their remote and hybrid work policies. Organizations are working hard to balance two competing ...
Read More
Compliance
PUBLISHED
August 8th, 2025
DOL Issues Updated Model Employer CHIP Notice
DeAnn Deck
The U.S. Department of Labor (DOL), through its Employee Benefits Security Administration (EBSA), has released a new model Employer CHIP Notice with information current ...
Read More
Benefits+
PUBLISHED
August 7th, 2025
How Employers Should Handle MLR Rebates
DeAnn Deck
The Affordable Care Act (ACA) established medical loss ratio (MLR) rules to help control health care coverage costs and ensure that enrollees receive value ...
Read More
Compliance
PUBLISHED
August 6th, 2025
ACA Affordability Percentage Will Increase for 2026
DeAnn Deck
The IRS released Revenue Procedure 2025-25 to index the contribution percentage in 2026 for determining the affordability of an employer’s health plan under the ...
Read More