The CARES Act and subsequent legislation temporarily allowed HDHPs to cover telehealth and other remote care services before the deductible was met – without affecting participants’ eligibility to contribute to an HSA. This flexibility, however, only applied to plan years starting before January 1, 2025. As a result, HDHPs with plan years beginning in 2025 were required to reinstate the minimum deductible for telehealth services to preserve HSA eligibility. The OBBB offers permanent relief by allowing HDHPs to provide telehealth and remote care services on a first-dollar basis starting with plan years that begin after December 31, 2024. This permanent change resolves years of uncertainty and is a significant win for employers and benefit providers.
