Over the holiday season, many were anticipating Congress would extend relief for telehealth coverage under high-deductible health plans (HDHPs).
Unfortunately, it didn’t happen.
As we step into the new year, here’s a breakdown of what this means for employers offering HDHPs paired with Health Savings Accounts (HSAs).
Where Things Stand Now
As of mid-January, there is no extended relief allowing HDHPs to cover telehealth services with little or no cost-sharing without affecting HSA eligibility. Under current rules, employees with HDHPs must meet their deductible before the plan covers non-preventive care services. Telehealth services, which often have low or no costs, don’t typically fall under the category of preventive care.
This creates a challenge: if telehealth services are offered at no or reduced cost before the deductible is met, the HDHP might no longer qualify as HSA-compatible. Without a qualified HDHP, employees cannot open or contribute to their HSAs.
What Employers Need to Do
Until Congress takes action to extend or retroactively apply telehealth relief, employers must navigate these rules carefully:
Charge for Telehealth Services:Employers offering telehealth or virtual care as part of their HDHP should ensure that the fair market value of these services is charged to employees. This preserves the HDHP’s qualified status and maintains employees’ ability to contribute to their HSAs.
Maintain Flexibility:Employers should set up their plans to quickly adjust if Congress provides relief. For example, ensuring telehealth services can be offered at little or no cost again if legislation changes.
What’s Next?
It’s possible Congress may address this issue retroactively or extend the relief in the near future. For now, though, it’s crucial to remain compliant with the current rules to avoid jeopardizing HSA eligibility for employees.
A Balancing Act
Telehealth has been a vital resource for employees, especially in recent years, making it frustrating for both employers and employees to face these hurdles. Until there’s further guidance or legislative action, employers must balance offering accessible telehealth services while ensuring their HDHPs remain HSA-compatible.
Stay tuned for updates, as this is a rapidly evolving area. Employers should consult their compliance experts to ensure they’re navigating these changes effectively.
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