The Alliance urged the Internal Revenue Service (IRS) to include guidance on an expired pandemic-era policy that enabled employers to provide telehealth services on a pre-deductible basis to individuals with high-deductible health plans coupled with a health savings account (HDHP-HSA) in its 2025-2026 Priority Guidance Plan.

As you may know, Section 3701 of the CARES Act created a temporary safe harbor that allowed employers and health plans to provide pre-deductible coverage of telehealth services for individuals with a high-deductible health plan coupled with a health savings account (HDHP-HSA) for the more than 32 million Americans. In December 2022, Congress extended this flexibility through December 31, 2024. In a letter to the IRS, members of Congress expressed concern about the cliff for patients when this policy expired. The concern brought forth by the members of Congress has come to pass and this important policy ended December 2024.

Read the letter here or below:

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