"Upon the expiration of this temporary CARES Act relief, plans will need to be sure to apply prior limitations to the use of telemedicine within an HSA-compatible high deductible health plan, to avoid violation of IRS 'first dollar rules' requiring that the HSA participant first satisfy his/her deductible before receiving plan coverage for most non-preventive services. In addition, plans will need to be sure to follow rules that require the plan to charge a reasonable fee and apply charges to the deductible and out-of-pocket maximums."

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