Signed into Law: July 4, 2025, by President Trump

The One Big Beautiful Bill Act (OBBB) introduces several changes impacting employee benefit plans. Here are the key provisions:

• Telehealth Services:
  • Permanently allows first-dollar coverage for telehealth services under High Deductible Health Plans (HDHPs) without affecting Health Savings Account (HSA) eligibility.
  • Retroactively reinstates the CARES Act telehealth provision that expired on December 31, 2024.
• Marketplace Plans Eligibility:
  • Starting January 1, 2026, all Bronze and Catastrophic plans available through the Marketplace will qualify as HDHPs for HSA purposes, expanding HSA access.
• Direct Primary Care:
  • Starting January 1, 2026, direct primary care services for a fixed fee up to $150 a month for individuals and $300 per month for a family will no longer be considered disqualifying coverage for HSA purposes.
  • These services must not include general anesthesia, extensive lab services, or prescription drugs.

Dykema View: These HSA changes ease the eligibility rules on individuals to make and receive HSA contributions while improving HDHP coverage by allowing first-dollar coverage for certain items and direct primary care options. Employers with telehealth services may decide to take advantage of this retroactive change for this year and even reimburse employees if they paid for telehealth services that can now be provided free of charge retroactively to January 1, 2025, without disqualifying the HSA.

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