The One Big Beautiful Bill Act (OBBBA), is more than just a sweeping economic and policy reform. Embedded within the bill are several impactful updates related to health and welfare benefits that will affect both employers and employees in meaningful ways.
Here’s a summary of some key provisions:
Permanent Telehealth Safe Harbor for HSA-Compatible HDHPs
Effective for plan years beginning on or after January 1, 2025, high-deductible health plans (HDHPs) that are HSA-qualified can permanently offer first-dollar coverage for telehealth services without jeopardizing Health Savings Account (HSA) eligibility. This change builds on temporary relief measures from the COVID-19 era and provides lasting certainty for employers and plan sponsors. As a reminder, employers are permitted, but not required, to cover telehealth services at no cost to HSA-eligible employees.
Direct Primary Care (DPC) Arrangements and HSA Eligibility
Beginning in 2026, employees enrolled in a Direct Primary Care (DPC) arrangement, a model that typically involves a fixed monthly fee for access to primary care, will remain eligible to contribute to a Health Savings Account (HSA), provided the monthly fee does not exceed $150 for individuals or $300 for families (which will be adjusted annually for inflation). These fees may also be paid directly from HSA funds. There are some exceptions to what can be offered by DPC primary care services. They don’t include procedures that require general anesthesia, prescription drugs (other than vaccines), or laboratory services not typically administered in an ambulatory primary care setting. We anticipate additional federal regulations/guidance on this new DPC/HSA provision.
Expanded HSA Eligibility for ACA Plans
As of January 1, 2026, Bronze and Catastrophic plans offered through the Affordable Care Act (ACA) Marketplace will be treated as HSA-compatible HDHPs. This change significantly broadens HSA access for the more than 7 million individuals currently enrolled in these plans.
Increased Dependent Care FSA Contribution Limits
For the first time since 1986, the maximum contribution limit for Dependent Care Flexible Spending Accounts (FSAs) will increase. Beginning in 2026, the annual cap will rise from $5,000 to $7,500 ($3,750 for married individuals filing separately). This adjustment is a significant benefit for working families managing childcare expenses.
Other Noteworthy Considerations
Certain other provisions in the OBBBA, including proposed Medicaid funding cuts and measures aimed at reducing enrollment in ACA Marketplace Exchange plans, may indirectly impact the employer-sponsored health insurance market. Specifically, these changes could lead to an increase in employees enrolling in employer-sponsored coverage, placing additional cost and enrollment pressures on employer health plans.
Next Steps for Employers
Employers should begin preparing for these changes by considering the following actions:
- Telehealth integration as a long-term strategy. The telehealth safe harbor is here for good! Employers should actively let employees know about this option. It’s not only a convenience, but it can also be a huge cost saver when paired with an HSA-eligible plan.
- Review and align plan documents and policies. Groups will need to consult with their insurance carrier to determine if the carrier will permit reinstatement of telehealth/HSA relief for the 2025 plan year and going forward.
- Evaluate offering Direct Primary Care (DPC). This option can appeal to employees seeking high-quality, yet affordable care at a flat fee.
- Adjust payroll systems and plan documentation. Modifications will need to be made for the new dependent care FSA limits, and begin informing employees ahead of the 2026 plan year.
Conclusion
The One Big Beautiful Bill Act represents one of the most significant expansions of HSA access and health benefit flexibility in over two decades. From telehealth and DPC eligibility to higher dependent care FSA limits, the legislation paves the way for more modern, inclusive, and family-friendly benefit offerings.
Need guidance implementing these updates? Silberman Group is here to support your team in navigating the new landscape and optimizing your benefit strategy. Reach out to the SG team to learn more.
