H.R.1 - 119th Congress (2025–2026) One Big Beautiful Bill Act (OBBBA)
Telemedicine Before Meeting a High-Deductible Health Plan’s (HDHP) Deductible
Overview
On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. A key health-related provision in this legislation is the permanent extension of first-dollar coverage for telemedicine services under High-Deductible Health Plans (HDHPs). This policy, originally introduced during the COVID-19 pandemic in 2020, allows telemedicine services to be covered without requiring plan participants to meet their deductible first. The provision was reinstated retroactively to January 1, 2025, and made permanent.
Legislative History and Evolution
This telemedicine benefit has experienced several changes over time, starting with the CARES Act, followed by temporary extensions with some interruptions through the Consolidated Appropriations Acts of 2022 and 2023. The OBBBA now ensures that first-dollar telemedicine remains available under HDHPs without jeopardizing the ability of employers or employees to contribute to Health Savings Accounts (HSAs).
Optional Participation for Self-Funded Plan Sponsors
It’s important to emphasize that, as with the previous safe harbor, this coverage is optional for self-funded plan sponsors and not mandatory.
Implementation and Next Steps
If your qualified HDHP currently covers telemedicine services—such as Teladoc or Atrium Urgent Care Video Visits—but only after the deductible is met, and you want to implement the first-dollar telemedicine benefit, a plan amendment will be required. Please contact your Account Manager for assistance with this process.
Reference
For more details on this legislation, please refer to Sec. 71306. Permanent Extension of Safe Harbor.