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March 23, 2022

First Dollar Coverage for Telehealth Extended

Donna Wilkinson
Donna Wilkinson
General Counsel

On March 15, 2022, President Biden signed into law the Consolidated Appropriations Act of 2022 (the “Act”), which restores the ability for high deductible health plans to pay for telehealth services before a covered individual satisfies the plans annual deductible. This means an individual can receive telehealth services without regard to the annual deductible and still be eligible to contribute to a health savings account (HSA). The Act restores this favorable treatment temporarily beginning April 1, 2022 through December 31, 2022.

Previously the CARES Act had temporarily amended IRS Code Section 223 to permit HDHPs to pay for telehealth services before the deductible was satisfied, but the CARES Act exception expired on December 31, 2021.

The new Act does not address the period from January 1, 2022 to March 31, 2022.

There are ongoing efforts to have this favorable treatment enacted permanently but at this time the Act’s provision sunsets December 31, 2022.

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