Telehealth Benefits Not Disqualifying Coverage for an HDHP through 2024

Insights | Telehealth Benefits Not Disqualifying Coverage for an HDHP through 2024

Among the provisions in the omnibus spending bill signed by President Biden on December 29, 2022, is an extension of telehealth relief provided to participants of high deductible health plans (HDHP).  The relief allows participants to receive telehealth services covered at 100% without jeopardizing an individual’s eligibility to make health savings account contributions. The original relief set to expire on December 31, 2022, has been extended for an additional two years.

Relief is Temporary

Just like previous relief, this relief is again temporary.  The relief for HDHP plan participants allowing coverage of telehealth services at 100% prior to the plan deductible being met will continue through December 31, 2024.  It is believed that more permanent guidance will be available prior to the end of the extension. For now, employers offering the relief will need to be mindful of the deadline when reviewing plan coverage for 2025.       

Additional Provisions

The new law also includes provisions to end the requirement that providers be licensed in the same state as the patient receiving care.  This allows more types of practitioners to provide telehealth services. The law also permits audio-only telehealth services and delays the in-person requirement for mental health patients seeking treatment through telehealth. These changes are welcome and intended to allow more individuals to access care through telehealth.

This Relief is Discretionary

Providing telehealth services free of charge prior to the deductible through an HDHP is not required.  A large majority of health plans and employer plan sponsors provided this relief when it initially became available in 2020, but some employers chose not to offer the relief when it was extended earlier this year.  Employers that wish to offer the relief now may do so. 

Employer Action

This relief once again comes at the end of the year.  Fully insured employers should check with their insurer to understand if the insurer intends to make the relief available as part of their plans or offerings.  Self-funded plan sponsors will need to contact their claims administrators to potentially request an administrative change to extend coverage and to amend their plan documents to include coverage for telehealth services.  HORAN is working with its vendor partners to understand the options available to both fully-insured and self-funded employer plan sponsors. As a first step, employers should contemplate whether they wish to offer the relief if it is available.


Please reach out to your HORAN representative with additional questions at 800.544.8306.

The information contained in this document is informational only and is not intended as, nor should it be construed as, legal or accounting advice. Neither HORAN nor its consultants provide legal, tax nor accounting advice of any kind. We make no legal representation, nor do we take legal responsibility of any kind regarding regulatory compliance. Please consult your counsel for a definitive interpretation of current statute and regulation and their impact on you and your organization.