OBBBA Brings Changes for Health Benefit Plans

On July 4, 2025, President Trump signed new legislation into law, the One Big Beautiful Bill Act (OBBBA).  Here are a few provisions of the bill that relate to health benefit plans:

• First-dollar telehealth and other remote coverage was reinstated and made permanent for HSA-qualifying high-deductible health plans (HDHP) beginning with plan years after December 31, 2024.  This option is available even if the cause of the telehealth visit is not preventive, without jeopardizing the ability of an individual to contribute to an HSA.
• Direct primary care (DPC ) models of coverage are no longer a form of disqualifying coverage for purposes of HSA eligibility.  With DPC models, a monthly fee covers services like office visits for acute illnesses or chronic-condition management.  Therefore, a DPC effectively provides first-dollar coverage for these non-preventive services, which conflicts with the HSA eligibility requirement that no other plan cover such expenses before the deductible.  Beginning in 2026, DPC arrangements will be HSA compatible, provided the fees do not exceed $150/month for individual coverage or $300/month for family coverage (indexed).  Further, DPC fees are a qualified medical expense that can be paid tax-free from the HSA.
• After nearly four decades, the maximum contribution to a dependent care FSA has been raised to $7,500 ($3,750 for individuals who are married and filing separately) for plan years beginning on or after January 1, 2026.  Congress set the dependent care FSA limit at $5,000 in 1986 without indexing it to inflation, and the new limit is not indexed either.

If you have questions about these provisions of the OBBBA, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.