Besides ensuring the federal government remains fully funded, President Biden’s signature yesterday on the Continuing Appropriations Act, 2023 (CAA 23) contains several provisions that will directly impact health and retirement benefit plans. First, CAA 23 enacts the Setting Every Community Up for Retirement Enhancement 2.0 Act (SECURE 2.0) to provide flexibility to employer-sponsored qualified retirement plans. Second, CAA 23 will extend recent guidance that permits certain telehealth benefits to be provided on a first-dollar basis under a high-deductible health plan (HDHP) without disqualifying the recipient from being eligible to contribute to a health savings account (HSA). Here are the 10 most significant items that employer plan sponsors need to know about CAA 23.
1. Telehealth Coverage and HSAs
General rules that govern HSAs disqualify anyone who has group health coverage other than under an HDHP which would require someone to first meet the applicable deductible before receiving health services. So, an individual who receives telehealth and similar remote services before meeting a deductible under an HDHP would be ineligible to contribute to an HSA.
Relief has been in place under the CARES Act and CAA, 2021 that prevents first-dollar telehealth coverage under an HDHP from being deemed disqualifying, but it was set to expire after December 31, 2022. CAA 23 extends relief through plan years starting after December 31, 2022, but before January 1, 2025.
Plan sponsors...
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