Employee Benefits
The One Big Beautiful Bill Act Brings Beautiful Relief for Telehealth Coverage
By Sara Van Houten
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the “Act”) into law. The Act makes permanent the COVID-era safe harbor that allowed high deductible health plans (“HDHPs”) to provide first-dollar coverage for telehealth and other remote care services. Congress previously had extended the COVID-era safe harbor on several occasions as described in our SW Benefits Update “High Deductible Health Plan Telehealth Relief, Extended Again!” However, it declined to do so for plan years beginning on or after January 1, 2025. This left many employers disappointed that they no longer could offer telehealth coverage and other remote care services to HDHP participants on a pre-deductible basis without rendering them ineligible to contribute to their HSAs.
The Act provides welcome relief for employers and a permanent extension of the telehealth safe harbor effective for plan years beginning after December 31, 2024. This means that beginning January 1, 2025, employers can provide telehealth and other remote care services to HDHP participants on a pre-deductible basis without making them ineligible to contribute to their HSAs.
In light of this change, employers may want to consider the following:
- The Act permits, but does not require, employers to provide coverage under their HDHPs for telehealth and other remote care services on a pre-deductible basis beginning on January 1, 2025.
- Employers who wish to provide this coverage should consider amending their HDHPs to cover telehealth and other remote care services on a pre-deductible basis and communicating the change to HDHP participants through a revised summary plan description or a summary of material modifications.
- Although the Act permits such coverage effective as of January 1, 2025, employers should consider whether to make the change retroactive to January 1, 2025 (which likely would require reprocessing telehealth and other remote care claims incurred on or after January 1, 2025 through the date of the plan amendment) or effective as of the date on which the employer adopts the plan amendment.
