In a bit of an on again off again status, telehealth and high deductible health coverage have had a symbiotic relationship meaning that first dollar coverage for any telehealth virtual or other type of remote care could be provided without jeopardizing HSA eligibility.
This temporary provision began at the beginning of COVID and has continued in fits and starts. Most recently, the Consolidated Appropriations Act of 2023 authorized first dollar coverage of telehealth and remote care for plan years beginning on or after January 1, 2023, and ending for plan years beginning in 2025. What this means for plan years beginning in 2025 is telehealth and related remote services will need to be subject to the minimum HSA statutory deductible in order to preserve HSA eligibility.
As a reminder, below are the 2024 and 2025 HSA annual deductible amounts.
2025 Individual | 2025 Family | 2024 Individual | 2024 Family | |
HDHP annual deductible | $1,650 | $3,300 | $1,600 | $3,200 |
HDHP annual out-of-pocket limit | $8,300 | $16,600 | $8,050 | $16,100 |
Contribution limit | $4,300 | $8,550 | $4,150 | $8,300 |
While there is significant bi-partisan support for continuing first dollar coverage of these types of services, in the absence of congressional action, it will no longer be permitted.
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