Overview
On July 4, 2025, the president signed the One Big Beautiful Bill Act (H.R. 1) into law. Among many other healthcare provisions, the bill permanently extends the telehealth safe harbor for high-deductible health plans (HDHPs) for plan years beginning after December 31, 2024. The permanent telehealth safe harbor is a big win for telehealth providers, health plans, and participants, many of whom advocated for its reinstatement to provide telehealth services at low or no cost to HDHP participants. The telehealth HDHP safe harbor expands access to telehealth and other remote care services for millions of individuals and dependents who are covered by HDHPs, which are often the lowest cost and most popular of the coverage options that employer-sponsored group health plans offer.
The previous safe harbor temporarily permitted HDHPs to cover telehealth and remote care services on a first-dollar basis without jeopardizing eligibility for health savings account contributions through December 31, 2024. After months of negotiations and advocacy from digital health and employer groups, the permanent extension was included in the bill and made retroactive. This means there was no interruption in the safe harbor, and HDHPs may continue covering these services without cost-sharing.
As a result of the permanent extension of the telehealth HDHP safe harbor, digital health and telehealth providers, virtual and remote care providers, employer plan sponsors, insurers, and third-party administrators may reassess and update their services and coverage for HDHP participants. For example, employer plan sponsors may elect to reinstate free or low-cost coverage for telehealth services retroactively to January 1, 2025, or choose to do so prospectively for the next plan year, if at all. Telehealth providers, insurers, and third-party administrators may wish to work with their employer and health plan partners to update their services and plan administration to reflect the potential increase in demand for telehealth and remote care services from HDHP participants, who can now access these services with no cost-sharing prior to satisfying the applicable deductible.
For more information or to discuss how the permanent telehealth HDHP safe harbor impacts your organization, contact the authors of this article or your regular M+ or McDermott contact.
