For important information and updates on COVID-19, please click here.
Congress recently passed a $1.5 trillion governmental funding package that included a provision to permit employers and plan sponsors that offer high deductible health plans (HDHPs) to provide first-dollar telehealth and other remote care services (waive the deductible) for the period from April 1, 2022 through December 31, 2022, without causing participants to lose health savings account (HSA) eligibility. This extension is of interest to employers and plan sponsors with HDHPs who may want to take advantage of this optional relief.
Background: General Rules and Short-term Extensions
Under the general rules, for an individual to be eligible to make or receive contributions to an HSA, the individual must be covered by an HDHP. Typically, this type of HSA-qualified HDHP cannot pay for covered services, except for specified preventive care, until the participant meets the plan’s deductible. Coverage provided under the health plan before the minimum deductible is satisfied would make plan participants ineligible to make or receive HSA contributions. Recent exceptions to the rule are as follows:
Next Steps
The CARES Act and CAA 2022 relief provisions are optional, so it is left to each employer and plan sponsor with an HDHP to determine whether to extend the deductible waiver for telehealth and other remote care. Insurance carriers will make the determination under a fully insured plan as to whether they will adopt the extension. Self-insured plan sponsors must coordinate with their TPA/stop-loss provider in order to implement the plan design change as deemed appropriate for a portion of the year.
Conner Strong & Buckelew will provide alerts and updates as new information becomes available. Please contact your Conner Strong & Buckelew account representative toll-free at 1-877-861-3220 with any questions. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.