President Biden recently signed the Consolidated Appropriations Act, 2023 ("CAA 2023") into law. The CAA 2023 includes an extension of the exclusion of telemedicine as disqualifying other health coverage when provided in conjunction with a high deductible health plan (HDHP) for HDHP plan years that begin in 2023 and 2024. This extends the existing telemedicine relief that was set to expire on December 31, 2022.
This Alert summarizes the issue of telemedicine as disqualifying other health coverage, prior COVID-19 telemedicine relief, and the scope of the new extension.
