A spending bill signed into law on March 15, 2022, extends 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. This extension applies to any telehealth services from April 2022 through the end of the year.
HSA contribution rules limit the types of health coverage that eligible individuals may have. As a general rule, telemedicine programs that provide free or reduced-cost medical benefits before the HDHP deductible is satisfied are disqualifying coverage for purposes of HSA eligibility.
However, effective in 2020, for plan years beginning before 2022, the Coronavirus Aid, Relief and Economic Security Act (CARES Act) allowed HDHPs to provide benefits for telehealth or other remote care services before plan deductibles have been met. This meant that HDHPs could provide coverage for telehealth services before the minimum deductible was reached without jeopardizing plan participants’ eligibility for HSA contributions. This rule expired for plan years beginning in 2022.
Impact of the Extension
Under the extension, HDHPs may choose to waive the deductible for any telehealth services from April 2022 through the end of 2022 without causing participants to lose HSA eligibility. This provision is optional; HDHPs can continue to choose to apply any telehealth services toward the deductible.
Note that telemedicine services provided between Jan. 1, 2022, and April 1, 2022, must still be counted toward the HDHP deductible to avoid impacting participants’ eligibility for HSA contributions.