Learn more about Congress Extends Telehealth Relief for HDHPs and Upcoming ACA Reporting Deadlines:
CONGRESS EXTENDS TELEHEALTH RELIEF FOR HDHPS
The Consolidated Appropriations Act, 2023
(CAA) extends the ability of high deductible
health plans (HDHPs) to provide benefits for
telehealth or other remote care services
before plan deductibles have been met
without jeopardizing health savings account
(HSA) eligibility. This extension applies for
plan years beginning after Dec. 31, 2022,
and before Jan. 1, 2025.
Background
In general, telehealth programs that
provide free or reduced-cost medical
benefits before the HDHP deductible is
satisfied are disqualifying coverage for
purposes of HSA eligibility. However, the
Coronavirus Aid, Relief and Economic
Security Act (CARES Act) allowed HDHPs to
provide benefits for telehealth or other
remote care services before plan
deductibles were met, effective for plan
years beginning before Jan. 1, 2022.
A spending bill extended this relief to
telehealth services provided in months
beginning after March 31, 2022, and before
Jan. 1, 2023. The CAA further extends this
first-dollar coverage for telehealth services
to plan years beginning after Dec. 31, 2022,
and before Jan. 1, 2025.
Impact of Extension
Due to this extension, HDHPs may choose
to waive the deductible for any telehealth
services for plan years beginning in 2023
and 2024 without causing participants to
lose HSA eligibility. This provision is
optional; HDHPs can continue to choose to
apply any telehealth services toward the
deductible. Note that there is a gap for non-calendar-year plans from Jan. 1, 2023
(when the spending bill’s extension
expired), to the start of the 2023 plan year,
during which this temporary relief for
telehealth services does not apply.
UPCOMING ACA REPORTING DEADLINES
Employers subject to Affordable Care Act
(ACA) reporting under Internal Revenue
Code Sections 6055 or 6056 should prepare
to comply with upcoming reporting
deadlines. For the 2022 calendar year,
covered employers must:
• Furnish statements to individuals by March 2, 2023
; and
• File returns with the IRS by Feb. 28, 2023
(or March 31, 2023,
if filing
electronically).
Penalties may apply if employers are
subject to ACA reporting and fail to file
returns and furnish statements by the
applicable deadlines.
The following employers are subject to ACA
reporting under Sections 6055 and 6056:
• Employers with self-insured health plans
(Section 6055 reporting)
• Applicable large employers with either
fully insured or self-insured health plans
(Section 6056 reporting)
In addition, the IRS has finalized an
alternative method for furnishing
statements to individuals under Section
6055. Employers using this method must
post a notice on their websites stating that
individuals may receive a copy of their
statement upon request. For 2022
statements, this notice must be posted by
March 2, 2023, and generally remain
posted through Oct. 17, 2023.
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