News & Analysis as of

HDHPs Safe Harbors

McDermott Will & Schulte

A win for telehealth providers, health plans, and participants: HDHP telehealth safe harbor permanently reinstated

On July 4, 2025, the president signed the One Big Beautiful Bill Act (H.R. 1) into law. Among many other healthcare provisions, the bill permanently extends the telehealth safe harbor for high-deductible health plans (HDHPs)...more

Proskauer - Employee Benefits & Executive...

Down to the Wire: Will We Have HSA with Pre-Deductible Telehealth in 2025?

The telehealth services safe harbor for high deductible health plans (“HDHPs”) will expire for plan years starting on or after January 1, 2025, absent Congress passing legislation extending or making the safe harbor...more

Holland & Knight LLP

IRS Clarifies HDHP Coverage of COVID-19 Testing, Treatment Before Deductible

Holland & Knight LLP on

The IRS recently issued Notice 2023-37 (Notice) relating to pre-deductible coverage of COVID-19 testing and treatment under high-deductible health plans (HDHPs). Specifically, the Notice establishes a 2024 expiration date for...more

Proskauer - Employee Benefits & Executive...

A New Normal? Omnibus Bill Extends High Deductible Health Plan Telehealth Safe Harbor

The Consolidated Appropriations Act of 2023 (“CAA 2023”), signed into law on December 29, introduced sweeping reforms to the employee benefits landscape. Not only do the CAA 2023’s “SECURE 2.0” provisions make some...more

Woodruff Sawyer

Compliance Alert: Telehealth Safe Harbor Extended Beyond Calendar Year 2022

Woodruff Sawyer on

On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023 (“CAA, 2023”), into law. The CAA 2023, which is largely a bipartisan spending bill, includes a new telemedicine safe harbor similar to...more

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