Expiring telemedicine relief for HDHPs/HSAs

On March 15, 2022, President Biden signed the Consolidated Appropriations Act, 2022 ("CAA 2022") into law. The CAA 2022 included temporary relief excluding telemedicine as disqualifying other health coverage when provided in conjunction with a high deductible health plan (HDHP). However, this relief only applies from April 1, 2022 – December 31, 2022 without regard to an HDHP’s actual plan year.

This Alert summarizes the issue of telemedicine as disqualifying other health coverage, the expiring telemedicine relief under the CAA 2022, prospects for further relief, and employer considerations to preserve employee health savings account (HSA) eligibility beginning on January 1, 2023.