The bipartisan deal originally struck to prevent a government shutdown included a two-year extension allowing telehealth benefits at low- or no-cost before the deductible in an HSA-qualified plan. However, that deal ultimately did not pass, and what Congress settled on did not include an extension of telehealth relief for HSAs.
Applies To:
- Employers of all sizes with an HSA-qualified HDHP coupled with a telehealth benefit.
Go Deeper:
As a reminder, high deductible health plans (HDHPs) qualified to couple with a health savings account (HSA) can only allow payment for preventive care expenses before the federal minimum deductible is met. Otherwise, to be an HSA-qualified HDHP (or QHDHP), all non-preventive care must be subject to the deductible until the individual or family meets the federal minimum deductible. For telehealth, this means charging a fair market value (FMV) the remote care provider is willing to accept as payment in full for the care provided.
Since COVID, relief allowed QHDHPs to charge low- or no-cost sharing for telehealth without applying the deductible. However, unless Congress grants yet another extension, it looks like that relief is coming to a close.
Practical Impact to Employers:
Plan years beginning on or after January 1, 2025, need to plan on charging a FMV for non-preventive telehealth visits until the individual has met the federal minimum deductible required of QHDHPs.
If Congress eventually passes another extension, the employer should be ready to flip a switch allowing low- or no-cost sharing telehealth visits, possibly back to January 1, 2025.
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