The Consolidated Appropriations Act 2022 (“CAA 2022”), signed by President Biden on March 15, 2022, reinstated temporary relief for high-deductible (“HDHP”) health plans to provide pre-deductible coverage for services telehealth from April 1 to December 31. , 2022, with no impact on the eligibility of HDHP participants to contribute to their Health Savings Accounts (“HSA”).

In general, HDHP coverage of no-cost or low-cost telehealth services before the participant meets the minimum HDHP deductible (in 2022, $1,400 for single coverage and $2,800 for family coverage) would make participants HDHP ineligible to make HSA dues.

The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) temporarily authorized HDHP coverage of “telehealth and other remote care services” at no charge prior to satisfaction of the minimum HDHP deductible, without affecting the participants’ HSA eligibility. The CARES Act temporary relief expired for plan years beginning on or after January 1, 2022.

The 2022 CAA temporarily reinstated the relief provided by the CARES Act from April 1 through December 31, 2022. This additional relief applies only prospectively.

This means that for HDHPs whose plan years begin on or after January 1, 2022, this temporary relief generally does not apply to telehealth services that occurred from January 1 through March 31, 2022, and those telemedicine visits must be subject to the HDHP minimum deductible. . Plan sponsors are permitted, but not required, to adopt this temporary relief.

This relief for telehealth services is separate from the tax rules that allow HDHPs to provide coverage for preventive care, as well as diagnostic testing and treatment for COVID-19, before the applicable HDHP minimum deductible is reached. satisfied without affecting participants’ HSA eligibility. Please keep in mind that telehealth services for COVID-19 diagnostic services shall continue to be covered without cost sharing for the duration of the public health emergency declared by the Secretary of HHS, as noted here.