The Telehealth Extension Has Ended…For Now

During the COVID-19 crisis, newly-created relief allowed first dollar coverage for telehealth services under a high deductible health plan (HDHP) without ruining health savings account (HSA) eligibility. That relief was extended for plan years beginning prior to January 1, 2025. You can read our articles regarding the initial relief and subsequent extensions here, here, and here.

An earlier version of the 2025 budget bill included a two-year extension of this HSA telehealth safe harbor relief. However, that provision did not make it into the slimmed down version of the budget bill that was signed by President Biden in late December. The slimmed down budget bill was intended to serve as a stop gap to keep the Federal government running through March 14, 2025. Industry members are hopeful that when budget talks resume, a telehealth extension will be a part of that discussion.

For now, the telehealth relief has ended. For plan years beginning on or after January 1, 2025, pre-HDHP deductible coverage for telehealth services will disqualify an individual from contributing to an HSA unless another exception applies. If you have questions about the interactions between HDHPs, HSAs, and telehealth services, Foley can help.