New IRS Guidance on HSAs: What Employers Should Know Under the One Big Beautiful Bill Act
Health Savings Accounts (HSAs) continue to evolve as one of the most valuable tools in modern benefits strategies. With the passage of the One Big Beautiful Bill Act (OBBBA), employers and plan sponsors have been waiting for clarity on how recent legislative changes will work in practice.
The IRS recently released new guidance that helps answer many of those questions. While some updates confirm expected changes, others introduce important details that employers should understand moving forward.
Here’s what matters most.
Expanded Access to Telehealth Services
One of the biggest updates involves telehealth.
During the pandemic, temporary rules allowed certain telehealth services to be covered before an employee met their deductible without affecting HSA eligibility. The new guidance confirms that this flexibility is now permanent under OBBBA.
However, there is an important nuance:
Only telehealth services that meet specific regulatory definitions will qualify. Employers and plan sponsors should ensure that any telehealth offerings align with approved classifications to avoid unintended compliance issues.
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What this means in practice is that telehealth remains a strong and flexible option, but plan design and vendor alignment matter more than ever.
Direct Primary Care and HSA Eligibility
Another notable clarification involves Direct Primary Care (DPC) arrangements.
Under the new rules, individuals enrolled in certain direct primary care programs may still be eligible to contribute to an HSA. This is significant because DPC models have grown in popularity as employers look for ways to improve access and reduce overall healthcare costs.
The IRS guidance provides additional clarity around what qualifies as primary care services, generally describing arrangements that involve fixed fees covering common medical services like routine exams, urgent care, and basic treatment.
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For employers exploring alternative healthcare models, this may create new opportunities to combine innovation with tax-advantaged benefits.
Changes Affecting Bronze and Catastrophic Plans
The guidance also addresses how certain individual-market plans interact with HSA eligibility.
Specifically:
- Bronze and catastrophic plans available through an exchange may now be treated as high-deductible health plans (HDHPs) for HSA purposes, even if they don’t meet traditional deductible requirements.
- In some cases, individuals enrolled in similar plans outside an exchange may still qualify if they reasonably believe the plan is exchange-eligible.
This clarification expands flexibility but also adds complexity, making it important for employers to communicate eligibility rules clearly.
What This Means for Employers
Overall, the new guidance reinforces the growing role HSAs play in benefits strategies. Expanded flexibility around telehealth and primary care arrangements can improve access to care while maintaining tax advantages for employees.
At the same time, these updates introduce additional layers of detail that employers should keep in mind:
- Confirm telehealth programs meet regulatory definitions
- Review how alternative care models interact with HSA eligibility
- Ensure communications clearly explain eligibility rules
- Evaluate whether plan designs still align with organizational goals
As HSAs become more dynamic, intentional plan oversight becomes increasingly important.
The Maddock Perspective
At Maddock & Associates, we see this guidance as part of a broader shift toward more flexible, consumer-driven healthcare strategies.
HSAs continue to offer powerful advantages for both employers and employees. The opportunity now is to use this new flexibility thoughtfully, ensuring that expanded options improve access to care while maintaining clarity and compliance.
A periodic review of plan structure and communication strategies can help ensure your benefits continue to support your workforce effectively.
If you have questions about how these updates affect your current strategy, we’re always here as a resource.
For more insights, compliance updates, and practical guidance, explore the article, "IRS Publishes New HSA Guidance Under the One
Big Beautiful Bill Act" by Colin Clark in this month’s Benefitting You newsletter.
