Many telemedicine programs disqualify a person from making contributions to a Health Savings Account (HSA). Generally, telemedicine programs that have a $0 copay or low dollar copay will eliminate HSA eligibility. Typically, a telemedicine program must apply the full cost of the virtual visit to the deductible, or it can only cover limited benefits (e.g., preventive-only services, dental-only services) to preserve HSA eligibility.

Due to the COVID-19 national public health emergency, Congress enacted a law that allowed for a person to have coverage through any telemedicine program without it eliminating HSA eligibility. This was allowed in 2020 and 2021. A separate law was passed extending this provision in 2022 (Note: HSA eligibility was only available in 2022 between April 1, 2022, and December 31, 2022. There was gap in 2022 where HSA eligibility was not preserved between January 1, 2022, and March 31, 2022.).

Beginning in 2023, many telemedicine programs will again impact the ability for people to make contributions to an HSA. Congress, of course, could pass another law which could change the impact of telemedicine on HSA eligibility, but that has yet to occur and very well may not occur.

Because many health plans now have telemedicine embedded into their coverage, and many employers also offer telemedicine as a stand-alone benefit, it will be important to review any potential impact to HSA eligibility. It can be easy to overlook benefits that disqualify a person from making contributions to an HSA even if they
appear to be covered by a plan that is considered a qualified high deductible health plan (HDHP).