Telehealth and HDHPs: the lapsed safe harbor

Telehealth and HDHPs: One of the Balls Congress Dropped

The CR fiasco from last week has a number of casualties, one being no-cost telehealth visits for an HDHP.

Effective January 1, 2025, a major shift is coming for high-deductible health plans (HDHPs) with Health Savings Accounts (HSAs): Pre-deductible coverage for telehealth services will no longer qualify.

That means that a telehealth visit will have to be charged a reasonable amount if the member is still in their deductible portion or the plan will not be a qualifying HDHP.

Here’s what you need to know:

1. Your plan year start date matters.
Plans starting before January 1, 2025, can continue to offer pre-deductible telehealth coverage—but only until the end of the plan year. After that, telehealth services will be subject to regular cost-sharing rules.

2. HSA eligibility at risk.
Employers who continue pre-deductible telehealth coverage for plan years starting after December 31, 2024, will disqualify their plans for HSA contributions.

3. Legislative updates could take months.
While there’s hope Congress may revisit this flexibility, it’s not guaranteed—and any changes will take time.

What can you do now?

• Review your plan documents. Ensure compliance with the new rules.

• Communicate changes clearly. Let employees know how their telehealth benefits are impacted.

• Monitor legislation. Stay ahead of potential updates from Congress.

Telehealth has become a vital benefit. Work closely with your health plan administrator, consultant, and legal counsel to navigate these changes seamlessly.

Does your plan require any changes?