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
Compliance
PUBLISHED
April 17th, 2026
Q1 CHECK-IN: STATE EMPLOYEE LEAVE LAW DEVELOPMENTS
DeAnn Deck
In line with recent years, 2026 has so far been an active one for employee leave laws at the state level. Since the beginning ...
Read More
Compliance
PUBLISHED
April 16th, 2026
CMS FINAL RULE ELIMINATES CREDITABLE COVERAGE DISCLOSURE OBLIGATION FOR FOR ACCOUNT-BASED PLANS
DeAnn Deck
The Centers for Medicare and Medicaid Services (CMS) has released a final rule that exempts account-based plans such as health reimbursement arrangements (HRAs), health ...
Read More
News and Updates
PUBLISHED
April 14th, 2026
The MJ Companies Announces Partnership with the City of Boulder
The MJ Companies
DENVER (April 14, 2026) – The MJ Companies, a leading financial services firm serving clients for more than 60 years, has announced its partnership ...
Read More
Compensation and Total Rewards
PUBLISHED
April 7th, 2026
How a Campus Restaurant Is Redefining Student Employment
Julie Bingham and Student Isabella Brothers
Because so many Gen Z employees prize meaning and wellbeing in their work, it’s easy to overlook the fact that the same research shows ...
Read More
Compliance
PUBLISHED
April 3rd, 2026
Health Plan Notices – Rules for Electronic Delivery
DeAnn Deck
To access the full compliance overview and sample communication materials, please download them at the end of the article. Employers are increasingly using electronic ...
Read More
News and Updates
PUBLISHED
April 2nd, 2026
MJ Retirement Named As One of Nation’s Top DC Advisor Teams
The MJ Companies
MJ Retirement has been named to the prestigious National Association of Plan Advisors’ (NAPA) list of the nation’s top defined contribution (DC) Advisor Teams ...
Read More