As previously discussed in this blog, the waiver for no-cost telehealth services provided to HSA participants enacted as part of the CARES Act in 2020 was set to expire. As part of the recently passed omnibus spending bill, the waivers will be extended until December 31, 2024. Originally, the waivers were set to expire 60 days after the end of the public health emergency but were extended in March this year to the end of 2022. The waivers are designed to allow individuals to access telehealth services before their annual deductible was met and is vital for many individuals to access care during the pandemic.
This extension will continue to allow HDHP health plans to offer telehealth services at no-cost to participants without making them ineligible to contribute to HSAs. Due to the HSA prohibition on first-dollar, pre-deductible coverage, without the extension HDHP plans utilizing HSAs could not offer no-cost telehealth.
In addition to the extension, the new law includes provisions include ending the requirement that providers be licensed in the same state as the patient receiving care, allowing more types of practitioners to provide telehealth services, permitting audio-only telehealth services and delaying the in-person requirement for mental health patients seeking treatment through telehealth.
Employers who sponsor HDHPs and provide telehealth coverage without cost sharing will continue to have relief through December 31, 2024. As this relief is still only temporary, Employers will need to review their plans as we get closer to 2025 to see, what, if any changes will need to be made. It is hoped that more permanent guidance will be released prior to the new deadline.
If you have any questions about the new telehealth extension or any employee benefit issues, please contact any of Graydon’s benefits team.
