Free Telehealth Restored Under HSA Until 2023

Background

Individuals may contribute to an HSA if they are covered by a qualifying HDHP and do not have other disqualifying coverage. Generally, telehealth or other remote health care services are considered other health care coverage that, if provided before satisfaction of the required deductible, may be disqualifying for purposes of contributing to an HSA. 

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) were signed into law on March 27, 2020. Among other things, the CARES Act offered temporary relief related to telehealth and other remote care services when offered with an HDHP and HSA. Specifically, for plan years beginning on or before December 31, 2021, telehealth and other remote care services could be offered before satisfaction of the deductible without jeopardizing an individual’s eligibility to contribute to an HSA.

Employer Action

Employers offering HDHPs with HSAs should consider whether to re-implement (or continue) free telehealth as part of a benefit offering. Employers with calendar year plans may 

have already re-introduced a cost associated with telehealth for HDHP/HSA participants once the CARES Act relief expired and should consider whether to waive those costs again given the temporary nature of this relief. Additionally,  employers with non-calendar year plans should consider the administrative and communication burdens that may be imposed by providing relief that may expire prior to the end of the current plan year. 

It is important that employers review these changes with their carriers, Third Party Administrators and telehealth vendors to understand their approach and communicate any changes with participants.