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
Retirement
PUBLISHED
September 9th, 2026
Making it Easy Could Lead to Poor Outcomes
Doug Prince
Making things easier is usually a good thing: easier enrollment, easier reporting, easier access to benefits. But when it comes to retirement plans, sometimes making a ...
Read More
Compliance
PUBLISHED
August 28th, 2026
IRS PROPOSES RULES FOR DEPENDENT CARE FSA NONDISCRIMINATION TESTING
Bryan Gross
On Aug. 11, 2026, the IRS issued proposed rules addressing nondiscrimination testing requirements for dependent care flexible spending accounts (FSAs). This marks the first ...
Read More
Employee Benefits
PUBLISHED
August 13th, 2026
AN ICHRA MAY SOLVE A COST PROBLEM. BUT IS IT SOLVING THE RIGHT PROBLEM?
Courtney Hutchison
For employers facing rising healthcare costs, the search for sustainable benefits strategies has become increasingly urgent. Organizations are looking for ways to create more ...
Read More
Employee Benefits
PUBLISHED
August 12th, 2026
THE STOP-LOSS MARKET IS CHANGING. HERE’S WHERE EMPLOYERS SHOULD FOCUS.
Paige Beilby
If your most recent stop-loss renewal felt more challenging than usual, you’re not alone. Over the past year, I’ve had more conversations with employers ...
Read More
Compliance
PUBLISHED
August 7th, 2026
MEDICARE PART D CREDITABILITY UPDATE
Bryan Gross
Employers are not required to offer creditable prescription drug coverage, but they are required to determine and communicate creditable (or non-creditable) status to eligible ...
Read More
Compliance
PUBLISHED
July 24th, 2026
EBSA RELEASES AGENDA OUTLINING UPCOMING REGULATORY ACTIONS
Bryan Gross
On July 3, 2026, the Trump administration released its 2026 Regulatory Plan and Unified Agenda of Regulatory and Deregulatory Actions (Agenda), identifying its significant ...
Read More