ARTICLE
20 January 2025

The Telehealth Extension Has Ended…For Now

FL
Foley & Lardner

Contributor

Foley & Lardner LLP looks beyond the law to focus on the constantly evolving demands facing our clients and their industries. With over 1,100 lawyers in 24 offices across the United States, Mexico, Europe and Asia, Foley approaches client service by first understanding our clients’ priorities, objectives and challenges. We work hard to understand our clients’ issues and forge long-term relationships with them to help achieve successful outcomes and solve their legal issues through practical business advice and cutting-edge legal insight. Our clients view us as trusted business advisors because we understand that great legal service is only valuable if it is relevant, practical and beneficial to their businesses.
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.
United States Food, Drugs, Healthcare, Life Sciences

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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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