On July 4, 2025, Donald Trump signed the One Big Beautiful Bill (OBBB) into law. Although most have focused on the sweeping tax reform included in the OBBB, a number of key employee benefits provisions...

Seyfarth Synopsis: On July 4, 2025, Donald Trump signed the One Big Beautiful Bill (OBBB) into law. Although most have focused on the sweeping tax reform included in the OBBB, a number of key employee benefits provisions are included in the OBBB as well. Most significantly, the OBBB expands access to and eligible expenses payable from Health Savings Accounts (HSAs), solidifies first dollar coverage for telehealth under high-deductible health plans (HDHPs), and permanently increases the annual contribution limit for dependent care flexible spending accounts (FSAs) for the first time since 1986. Most of the benefits-related changes become effective January 1, 2026. This legal update provides an overview of the OBBB's employee benefits provisions and any actions that employers need to take for their employee benefit plans now or in the future.

First Dollar Telehealth Coverage Made Permanent (Effective January 1, 2025)

During the COVID-19 pandemic, the CARES Act temporarily allowed HDHPs to cover telehealth services on a first-dollar basis (i.e., without being subject to the deductible). This relief originally expired beginning in 2025. The OBBB retroactively and permanently reenacted this provision effective for plan years beginning after December 31, 2024, allowing (but not...

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