By: Kaitlyn MacLeod, Esq.

The CARES Act temporarily provided the ability for HSA-qualified High Deductible Health Plans (HDHPs) to offer first dollar telehealth benefits, regardless of whether the services were related to COVID-19 or preventive care. This optional allowance only applied to plan years beginning on or before December 31, 2021.

Under the CARES Act, if the plan year began on or after January 1, 2022, the telehealth provision would no longer be in effect, meaning that any non-preventive telehealth services provided after that date could not be offered at first dollar.

But fear not! The recently passed Consolidated Appropriations Act of 2022 temporarily extends the HSA relief, allowing HDHPs to provide first-dollar telehealth services between April 2022 and December 2022, regardless of the renewal date of the plan. The telehealth services do not need to be preventive or related to COVID-19 to qualify for this option. 

Plans are not required to adopt this – each plan can opt in to the temporarily waive the deductible for telehealth services without jeopardizing their HDHP status.

What happens if the plan did renew after December 31, 2021?  If the plan did renew on or after January 1, 2022, and did decide to utilize this option, there would be a gap in the ability to offer first dollar telehealth coverage for non-preventive services between January 1 and March 31, 2022.

HDHPs may opt for this extension between April and December 2022, but keep in mind that depending on the renewal date for the plan, there may be a gap for providing deductible waived telehealth coverage. For any gap between January 1 and March 31, 2022, the standard deductible will apply.

Questions on this temporary extension? We are here to help! Contact us at pgcreferral@phiagroup.com.