For a while, HDHP sponsors lived on short-term telehealth relief: cover virtual care before the deductible without wrecking HSA eligibility, then hope Congress extended the patch again. The One Big Beautiful Bill Act made pre-deductible telehealth/remote care flexibility permanent for plan years beginning on or after January 1, 2025, and Notice 2026-5 elaborates on how that interacts with the rest of the HSA rules.
What to tell employees
You can usually say: “Using telehealth the way our HDHP covers it should not, by itself, stop HSA contributions.”
You should not say: “Every app that chats with a clinician is automatically HSA-safe and free.”
Network rules, cost sharing, and what’s treated as preventive vs. diagnostic still matter. So does other coverage (that general-purpose FSA keeps crashing this party).
Sponsor to-do
- Confirm carrier SBCs and telehealth vendors match the plan’s intended pre-deductible stance.
- Update HDHP/HSA FAQs that still talk about “temporary COVID telehealth relief.”
- Train the people who answer the benefits phone — outdated scripts create more risk than outdated PDFs.
Permanence is helpful. Clear wording is what participants actually feel.