Compliance Bulletin – Telehealth Exception for HDHP/HSA Plans May Expire Soon

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In response to the COVID-19 pandemic, the U.S. Congress enacted legislation that temporarily allowed high deductible health plans (HDHPs) to provide benefits for telehealth services before plan deductibles were met. This relief became effective in 2020 and has been repeatedly extended. It currently applies to plan years beginning before Jan. 1, 2025.

Employers with HDHPs should review their health plan’s coverage of telehealth services to determine if changes should be made for the plan year beginning in 2025. Unless the relief is extended again, HDHPs must impose a deductible on telehealth services to be compatible with HSA contributions.
Also, any changes to telehealth coverage should be communicated to plan participants through an updated summary plan description or a summary of material modifications.

View and download the HR Compliance Bulletin