Last year the IRS provided guidance that permitted telehealth services to be offered under high-deductible health plans on a pre-deductible basis. Plan sponsors were permitted to amend their plan documents so participants could receive telehealth services at no cost or at a cost less than the normal deductible. This meant those individuals with HSAs could receive telehealth services at no cost or reduced cost without impacting their eligibility to contribute to their HSA.
Unless additional guidance is issued, this exception ends on December 31, 2021. Any plan sponsor that amended their plan to allow pre-deductible telehealth services should be preparing to amend their plan effective January 1, 2022 to remove this exception. From January 1, 2022 forward, telehealth services will need to be subject to the deductible in order for individuals to remain HSA eligible.
If you have any questions about this provision, or benefits in general, please contact any of Graydon’s employee benefits team.
