Important Update—Pre-Deductible Telehealth HSA Relief Ends on December 31, 2024: As discussed in our post below, although extension of the telehealth safe harbor was included in various bill drafts, the year-end spending bill signed into law on December 21, 2024 (American Relief Act, 2025) does not include pre-deductible telehealth relief. This means that the
For HDHPs, IRS Confirms Pre-Deductible COVID-19 Testing Coverage Will End Next Year
By Jennifer Rigterink & Jesse T. Foley on
In the most recent sign that special COVID-19 benefit plan rules are drawing to a close, last Friday, the IRS issued Notice 2023-37, which clarifies the scope of COVID-19 testing and treatment that can be provided on a pre-deductible basis under a high deductible health plan (HDHP) without impacting a participant’s ability to contribute to a health savings account (HSA). As a reminder, if an HDHP covers medical items and services before the participant satisfies the IRS minimum deductible (self-only or family), that coverage may disqualify the participant’s HSA contributions. Notice 2023-37 can be downloaded here.
A New Normal? Omnibus Bill Extends High Deductible Health Plan Telehealth Safe Harbor
By Katrina McCann & Jesse T. Foley on
The Consolidated Appropriations Act of 2023 (“CAA 2023”), signed into law on December 29, introduced sweeping reforms to the employee benefits landscape. Not only do the CAA 2023’s “SECURE 2.0” provisions make some significant changes for retirement plans, but CAA 2023 also extends the telehealth plan safe harbor for high-deductible health plans (“HDHPs”) that…
Congress Reopens Door For HSA With No-Deductible Telehealth, But With a Hole
By Aaron Weiss & Seth Safra on
Effective April 1, 2022, high-deductible health plans can once again offer first-dollar coverage for telehealth and other remote services without making participants ineligible for health savings account (“HSA”) contributions. The relief runs only through the end of 2022, and the regular high-deductible health plan requirements generally apply for the months of January through March 2022. …