| In late December 2022, President Biden signed legislation extending the ability of high-deductible health plans (HDHPs) to provide benefits for telehealth, or other remote care services, before plan deductibles have been met without jeopardizing health savings account (HSA) eligibility. The legislation extended this relief, originally set to expire on December 31, 2022, for plan years beginning after December 31, 2022 and before January 1, 2025. As background, HSA contribution rules require that a participant must be covered under a qualified HDHP plan in order make a contribution to their HSA. Plans that provided first dollar coverage including telemedicine services are not considered qualified HDHP plans. The Coronavirus Aid, Relief and Economic Security (CARES) Act allowed HDHPs to provide benefits for telehealth, or other remote care services, at either no cost or at a reduced cost without jeopardizing a plan participant’s eligibility for an HSA contribution. This relief initially expired for plan years beginning in 2022, but was extended for any telehealth service incurred from April 1, 2022 through December 31, 2022. As mentioned above, the legislation further extended this relief, originally set to expire on December 31, 2022, for plan years beginning after December 31, 2022 and before January 1, 2025. This latest extension appears to create a gap for non-calendar year plans because neither the immediate prior extension, nor this latest extension, will apply to the months of any 2022 plan year that fall in 2023. As such, telehealth or other remote care services could be disqualifying coverage from January 1, 2023 to the day before the first day of the applicable 2023 plan year. Please note that HDHPs are not required to take advantage of this relief, as it is purely optional. If you have any questions, please let me know. Happy New Year! |
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