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HDHP coverage

Telehealth before the HDHP deductible and HSA eligibility

Apply the permanent safe harbor for telehealth while keeping unrelated pre-deductible benefits under review.

HSA rule
For plan years beginning after December 31, 2024, an HDHP may provide telehealth and other remote care before the deductible without preventing HSA eligibility.

Check the plan-year start

Employer plan years do not always match calendar years. Confirm when the plan year begins and whether the benefit fits the remote-care category. The safe harbor concerns plan design, not every virtual purchase.

Continue the full HDHP review

Deductible, out-of-pocket, preventive-care, and other pre-deductible rules still matter. Telehealth relief does not authorize unrelated first-dollar treatment.

Example and common mistake

A noncalendar-year plan adds no-cost telehealth before its new plan year. Effective-date analysis matters. Treating every wellness subscription or remote device as covered by the safe harbor is the mistake.

Confirm the service fits the safe harbor

Review how the HDHP pays telehealth and other remote-care services before the deductible, the plan-year dates, and whether the benefit is actually part of the medical plan. The permanent rule applies to qualifying telehealth and remote care; it does not turn unrelated wellness subscriptions, devices, or broad reimbursement accounts into permitted coverage.

Keep the plan amendment or Summary of Material Modifications showing the benefit and effective date. Noncalendar-year plans deserve special attention around transitions. Continue testing all other HSA eligibility requirements, because a permitted telehealth feature cures only that feature's pre-deductible payment issue.

Questions to resolve

  • Is the pre-deductible benefit qualifying telehealth or remote care?
  • When did the plan provision become effective?
  • Are unrelated wellness, device, or reimbursement benefits being analyzed separately?

Federal authority record

Next HSA decisions

Preventive care before the HDHP deductibleHow to tell whether a health plan is HSA-qualified2026 HSA changes for Bronze plans, catastrophic plans, and direct primary care