News Archive

"OBBBA ... introduced several changes affecting HSAs, including a permanent safe harbor for pre-deductible telehealth and remote care, the designation of [ACA] Exchange bronze and catastrophic plans as HSA-compatible, and clarification that qualifying Direct Primary Care Service Arrangements (DPCSAs) do not disqualify individuals from HSA eligibility."  MORE >>

"[T]he new guidance [1] clarifies that the safe harbor does not extend to in-person services, medical equipment, or drugs furnished in connection with telehealth or other remote care services.... [2] clarifies how Direct Primary Care Service Arrangements (DPCSAs) interact with HSAs.... [3] provides that beginning January 1, 2026, bronze and catastrophic health plans, including those obtained through a health insurance exchange, will be treated as HSA-compatible, even if they don't meet the traditional high-deductible requirements."  MORE >>

"Effective for the 2025 plan year, OBBBA reinstated and made permanent COVID-19-era telehealth relief allowing HSA-compatible high-deductible health plans (HDHPs) to cover telehealth and other remote care services before the statutory minimum deductible is satisfied. Beginning Jan. 1, 2026, OBBBA also allows individuals enrolled in certain direct primary care service arrangements to remain eligible to make or receive HSA contributions and treats certain bronze and catastrophic plans as HDHPs. This article summarizes provisions of Notice 2026-5 most relevant to employers."  MORE >>

"The guidance addresses telehealth services, direct primary care arrangements and individual market coverage. [Notice 2026-5] does not break much new ground, but a few provisions are worth noting. [1] Telehealth safe harbor made permanent ... [2] Direct primary care service arrangements ... [3] Bronze and catastrophic plans."  MORE >>

"Plan sponsors should be collaborating with their payroll vendors and recordkeepers to understand how mandatory Roth catch-up contributions will be processed for high wage earners ... [If] at least one applicable retirement plan within a controlled group permits super catch-up contributions, all controlled group retirement plans must also permit super catch-up contributions.... By February 16, 2026, each HIPAA covered entity and business associate must update its Notice of Privacy Practices (NPP) ... Some section 409A corrections under Notice 2008-113 must be completed by year-end, making now the ideal time to identify and finalize correction of any lingering errors."  MORE >>

"Previously, enrollment in a direct primary care service arrangement typically disqualified individuals from HSA contributions.... Now, qualifying direct primary care service arrangements (DPCSAs) are no longer treated as health plans for HSA eligibility purposes. This means you can be enrolled in both a high deductible health plan (HDHP) and a qualifying DPCSA while maintaining your ability to contribute to an HSA."  MORE >>

"[Notice 2026-5] affirmed a permanent safe harbor provision allowing HSA holders to receive telehealth and other remote care services before meeting their deductible, while remaining eligible to contribute to an HSA, effective for plan years beginning on or after January 1, 2025. The notice also clarified that, as of January 1, 2026, bronze and catastrophic plans available through a health care exchange are considered HSA-compatible, regardless of whether the plans satisfy the general definition of a high-deductible health plan. The plans do not have to be purchased through an exchange to qualify for the relief."  MORE >>

"[T]he OBBBA made permanent the safe harbor allowing high-deductible health plans (HDHPs) to cover telehealth and other remote care services before the minimum deductible is satisfied without losing their HDHP status. These services are also considered disregarded coverage on a permanent basis and thus will not cause a loss of HSA eligibility. "  MORE >>

"While [Notice 2026-5] provides some helpful clarification, it points the public to other, not very straightforward, sources for determining which telehealth services may be provided ... [It] permits an individual who does not even purchase a bronze or catastrophic plan available through an Exchange to be HSA-eligible, but again, the guidance points the public to other sources to determine whether the rules are satisfied.... [T]he guidance on direct primary care arrangements ... suggests that, except for a narrowly defined arrangement, an individual cannot participate in a direct primary care arrangement and contribute to an HSA at the same time."  MORE >>

"Heath savings accounts (HSAs) are proving to be a way for many employers and employees to better control health care costs, thanks to their tax benefits, lower premiums, and long-term investment opportunities. Learn how to drive greater participation throughout the plan year."  MORE >>

"Under the bill, individuals who sign up for a bronze or catastrophic plan on the exchanges that's paired with an HSA will receive a contribution from the Centers for Medicare & Medicaid Services. For individuals making up to 700% of the federal poverty level, they will receive $1,000 if aged 18 to 49 and $1,500 if they're between the ages of 50 and 64."  MORE >>

"What's New: P.L. 119-21, July 4, 2025, amended Code section 223 to provide that: [1] An HSA eligible individual may have disregarded coverage (besides the HDHP) for telehealth and other remote care. [2] A plan will not fail to be treated as a HDHP by reason of failing to have a deductible for telehealth and other remote care services. The amendments apply to plan years beginning after 2024." [Also available: 2025 IRS Form 8889: Health savings Accounts]  MORE >>

"[Some] are pitching the accounts as an alternative to expiring enhanced federal subsidies that have lowered insurance premium payments for most Americans with [ACA] coverage. But legal limits on how HSAs can and can't be used are prompting doubts that expanding their use would benefit the predominantly low-income people who rely on ACA plans.... One group that would almost certainly benefit: a slew of companies selling expensive wellness items that can be purchased with tax-free dollars from the accounts."  MORE >>

"[T]he Health Savings Account (HSA) Consumer Protection Act [HR 6183] ... [would] [1] Remove the exception that permits HSA use for non-health care services without penalty at age 65.... [2] Place income limitations around the payroll tax exemption for HSA contributions.... [3] Require individuals to substantiate that their distributions from HSAs are for qualified medical expenses.... [4] Ensure that institutions offering HSAs do not charge excessive fees and meet basic transparency requirements[.]"  MORE >>

"[P]roposals have emerged from some Republicans in Congress to effectively repeal some or all of the ACA premium tax credits and replace them with contributions to Health Savings Accounts (HSAs) or something similar."  MORE >>

"[The authors] study how saving behavior responds to the Health Savings Account (HSA) 'catch-up' contribution provision, which raises HSA contribution limits for individuals aged 55 and older.... [They] find a sharp increase in contributions among those previously near the limit and smaller increases among unconstrained savers. Induced contributions ... do not appear to crowd out retirement savings. Responses are strongest among payroll contributors and long-term savers.... [M]arried couples do not appear to coordinate their HSA behavior to take advantage of the complex spousal rules governing catch-up contributions."  MORE >>

"[1] Catch-up 401(k) contributions for higher earners over 50 must be made to a Roth ... [2] 401(k), 403(b), and 457(b) plan contributions go up in 2026 ... [3] Traditional and Roth IRA limits for 2026 ... [4] Expanded savings for small businesses and the self-employed ... [5] Paper statement requirement ... [6] Health savings accounts (HSAs) ... 2025 year-end deadlines."  MORE >>

The IRS has now released all of the 2026 benefit limits, including both the cafeteria and health plan limits as well as all of the qualified retirement plan limits. Earlier this year, IRS also released the High Deductible Health Plan (HDHP) and Health Savings Account (HSA) limits. This chart shows all of these limits for 2025 and 2026.  MORE >>

"[A] handy chart (updated for this year) [describes] how each of these account types varies around eligible employers; eligible employees; the need for a plan document; who can make contributions to the account; this year's contribution limits (if any); the tax benefits to the employee and to the employer; and if investment earnings (if any) are taxed. [It also covers] funds availability to participants; any carryover provisions; portability of the account; eligible expenses to be reimbursed; substantiation requirements; and whether debit cards are available."  MORE >>

"The OBBB Act expands the permissible use of HSA funds ... Dependent Care FSA limit increased to $7,500.... Expansion of employer childcare tax credit.... Student loan repayments as qualified educational assistance.... Workplace benefits with limits on favorable tax treatment: Moving expenses.... Bicycle commuting reimbursements."  MORE >>

"[1] HSAs are not use-it-or-lose it ... [2] HSAs can provide more tax breaks than 401(k)s ... [3] You can invest the HSA money in mutual funds ... [4] You can open an HSA even if it isn't offered by your employer ... [5] HSA money can be used for even more expenses after retirement ... [6] You can use the HSA money for family members' medical expenses ... [7] You have an unlimited amount of time after you pay for medical expenses to reimburse yourself."  MORE >>

"As a reminder, these annual adjustments are permissive, meaning employers/plan sponsors are not required to adopt [the] plan limit adjustments within their plan. If an employer/plan sponsor chooses to adjust their employee contribution/reimbursement amounts, they should reflect such changes within their accompanying document(s) that describe the plan(s)."  MORE >>

"This article breaks down each update in plain language, helping HR leaders understand what's changing, what to review, and how to keep their benefits plans compliant. Learn how proactive HR teams use these annual updates to strengthen compliance processes and build employee trust."  MORE >>

"When employees use their HSA regularly, they are more likely to contribute funds, which, in turn, increases tax savings for both employee and employer ... Despite that mutual benefit, many employers may not realize that their employees are not only frustrated with the HSA experience, but also leaving money on the table."  MORE >>

"As an employer, helping your team understand the full scope of HSA-eligible expenses can dramatically improve benefit utilization, boost employee satisfaction, and reinforce your commitment to holistic wellness. Empower your workforce today by educating them about the many unexpected items eligible for HSA spending."  MORE >>