2026 Employee Benefits Market Outlook 14 The One Big Beautiful Bill Act and What It Means for Employers On July 4, 2025, a sweeping tax and spending bill, commonly referred to as the OBBBA , was signed into law. Although significantly pared down from its original draft version, the OBBBA includes a broad set of changes for employee benefit plans, most of which take effect in 2026. These changes expand options for existing employee benefit plans and present new benefit-related opportu- nities for employers to consider for 2026. Health Savings Accounts (HSAs) Significantly, the OBBBA expands access to HSAs, tax-advantaged medical savings accounts generally available to individuals who are enrolled in high-de- ductible health plans (HDHPs) and do not have other health coverage. The OBBBA permanently allows employers with HDHPs to provide benefits for tele- health and other remote care services before plan deductibles have been met without jeopardizing HSA eligibility. A pandemic-related relief measure tem- porarily allowed HDHPs to waive the deductible for telehealth services without impacting HSA eligibility; however, this bipartisan-supported relief expired at the end of the 2024 plan year. The OBBBA retroactively extends this relief, effective for plan years beginning after Jan. 1, 2025, and makes it permanent. Employers with HDHPs should review their health plans coverage of telehealth services and assess if changes should be made, considering the OBBBAs permanent extension. Any changes to telehealth coverage should be communicated to plan participants. Effective Jan. 1, 2026, the OBBBA further expands access to HSAs by allowing individuals with direct primary care (DPC) arrangements to make HSA con- tributions if their monthly fees are $150 or less ($300 or less for family coverage). These dollar limits will be adjusted for inflation each year. A DPC arrangement is a subscription-based health care delivery model where an individual is charged a fixed periodic fee for access to medical care consisting solely of primary care ser- vices. In addition, the OBBBA treats DPC fees as a medical care expense that can be paid for using HSA funds. Given this change, employers with HDHPs may
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