On July 4, 2025, President Trump signed into law the “One Big Beautiful Bill” Act (OBBB), a sweeping piece of legislation that significantly reshapes the landscape of tax policy and public health coverage. While the bill’s broader tax and healthcare implications have dominated headlines, employers and plan sponsors should take note of several key provisions that directly impact benefit plan design, compliance obligations, and workforce strategy.

High Deductible Health Plans and Health Savings Accounts

• Telehealth Coverage - The OBBB permanently restores the telehealth safe harbor that lapsed at the end of 2024. High deductible health plans (HDHPs) can now continue to waive deductibles for telehealth and other remote care services without disqualifying enrollees from eligibility to contribute to a health savings account (HSA). This change is retroactive to plan years beginning on or after January 1, 2025.
• Direct Primary Care - The OBBB expressly permits HDHP enrollees to participate in direct primary care arrangements without jeopardizing their ability to contribute to an HSA. The OBBB also allows for HSAs to reimburse the fees for “direct primary care service arrangements.” To qualify as a direct primary care service arrangement, the services provided under the arrangement must be limited to “primary care services” provided by a “primary care practitioner” for a fixed periodic fee. For this purpose, “primary care services” do not include (i) procedures that require the...

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