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August 1, 2026

Webinar Q&A: Your Top Questions About the New HSA Rules

Health Savings Accounts are undergoing some of the most significant changes in more than 20 years. Recent legislation and IRS guidance have expanded HSA eligibility, made the telehealth safe harbor permanent, clarified Direct Primary Care compatibility, and introduced other important updates that employers and brokers should understand before open enrollment. 

Our recent webinar generated dozens of excellent questions from employers and brokers. Here are answers to some of the most common topics.

Q. Can telehealth still be covered before the deductible?

A. Yes. High deductible health plans can permanently cover telehealth before the deductible without affecting HSA eligibility.

Q. Do Bronze Marketplace plans now qualify for HSAs?

A. Yes. Bronze and Catastrophic Marketplace plans purchased on the Exchange—and certain off-Exchange mirror plans—are now HSA compatible. This also applies to many plans purchased through an ICHRA.

Q. Can Direct Primary Care memberships be paid with HSA funds?

A. Yes, provided the arrangement meets IRS requirements and monthly fees stay within the allowable limits.

Q. Can HSA dollars pay insurance premiums?

A. Generally no.

There are four primary exceptions:

  • COBRA premiums
  • Health coverage while receiving unemployment benefits
  • Most Medicare premiums after age 65
  • Qualified long-term care insurance premiums

Q. Are products labeled "HSA eligible" always eligible?

A. No. Retailers don’t determine HSA eligibility. The IRS does. Employees should rely on IRS guidance and maintain appropriate documentation for eligible expenses.

Q. What should employers communicate during open enrollment?

A. Employees should understand:

  • Telehealth is now permanently HSA compatible.
  • More health plans qualify for HSAs.
  • Marketing claims around HSA-eligible products should be viewed carefully.
  • Contribution opportunities have expanded.

Q. What about GLP-1 medications?

A. This remains one of the biggest areas to watch. GLP-1 medications may be reimbursable through an HSA when prescribed for a qualifying medical condition. However, whether a high deductible health plan can cover them before the deductible without affecting HSA eligibility depends on plan design and evolving IRS guidance.

Q. Do these changes affect small employers?

A. Yes. The HSA eligibility rules apply regardless of employer size. Whether an employer has 10 employees or 10,000, the federal HSA rules remain the same.

Q. What should employers do next?

A. Before open enrollment, employers should review:

  • Plan documents
  • Eligibility procedures
  • Claims substantiation
  • Wellness reimbursement programs
  • Telehealth benefits
  • Direct Primary Care arrangements

Taking these steps now can help ensure employees receive the full benefit of the new HSA rules while maintaining compliance.

Still have questions?

Our team is here to help you understand how the new HSA rules may impact your organization. Contact Ameriflex to discuss your benefits strategy or start a proposal today.

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