"[I]ndividuals covered by an HDHP with no other disqualifying coverage remain HSA-eligible even if the plan pays non-preventive benefits prior to the individual satisfying the applicable minimum statutory HDHP deductible ... [and] HDHPs may pay non-preventive benefits prior to the individual satisfying the applicable minimum statutory HDHP deductible -- provided such benefits are required pursuant to the CAA (or other similar state law) surprise billing protection provisions."