New Benefits, Big Changes: What the OBBBA Means for HDHPs Telehealth, FSAs, HSAs & More
The recently passed One Big Beautiful Bill Act (OBBBA) brings a wave of important updates that will directly impact health plan administration, tax-preferred accounts, and telehealth accessibility, many of which take effect starting January 1, 2026. Thanks to the advocacy efforts of associations that RSA is a part of, several long-supported reforms have become law. Below, we break down what's changing and what to watch for in the future.
HDHPs and Telehealth Visits
RSA-Supported Legislation
• Current Policy: Telehealth visits under High Deductible Health Plans (HDHPs) apply to the deductible, and only after the deductible is met do copayments and coinsurance kick in.
• What's Changing: Retroactive to plan years beginning January 1, 2024, telehealth benefits through a HDHP allow for $0 copay before the deductible is met.
Important Caveat: Carrier discretion towards $0 copays will apply.
Direct Primary Care (DPC) and HSAs
RSA-Supported Legislation
• Current Policy: Payments for Direct Primary Care arrangements disqualify an individual from HSA contributions.
• What's Changing: DPC subscriptions will qualify as HSA-eligible expenses, up to $150/month for individuals and $300/month for families (adjusted annually for inflation). This unlocks tax-advantaged access to a growing model of patient-centered care. This takes place effective January 1, 2026.
Dependent Care FSA Limits
• Current Policy: Employees can contribute up to $5,000/year pre-tax (or $2,500/year if married filing separately) to a Dependent Care Flexible Spending Account (FSA).
• What's Changing: Effective January 1, 2026, employers may choose to adopt the new IRS maximum of $7,500/year (or $3,750/year if married filing separately).
Note: This new limit is not indexed for inflation.
Bronze & Catastrophic Exchange Plans and HSA Eligibility
• Current Policy: Exchange plans must comply with standard HDHP rules to be HSA-eligible.
• What's Changing: Starting in 2026, all Bronze and Catastrophic plans sold on the Exchange will automatically qualify as HDHPs, regardless of whether they meet existing deductible or cost-sharing thresholds.
Eligibility Criteria:
- Enrolled in a qualifying Exchange plan
- Not enrolled in Medicare Part A
- No disqualifying coverage
- Not claimed as a dependent on another's current-year tax return
Tax-Free Student Loan Repayments
• Current Policy: Under the CARES Act, employer-sponsored student loan repayment assistance was temporarily tax-free and set to expire in 2025.
• What's Changing: The benefit is now permanently codified under Section 127 Education Assistance Plan. Employers can contribute up to $5,250 per year, tax-free, toward an employee’s student loans.
Note: Requires a formal plan document and must meet nondiscrimination rules.
While the OBBBA included several impactful benefit enhancements, it's equally important to understand the provisions that were discussed during the legislative process and ultimately excluded from the final legislation. These items remain significant areas of interest for many employers, benefits professionals, and policymakers.
• Extension of Enhanced Premium Tax Credits for the individual market, which are set to expire at the end of 2025
• Codification of Individual Coverage Health Reimbursement Accounts (ICHRAs)
• HSA Expansion to wearable technology and working seniors
Employer Takeaways
• Plan Ahead and engage your benefits consultant about 2026 plan strategy and updates.
• Educate employees about new HSA flexibility, DPC options, and benefit expansions.
• Review & update plan documents and administrative procedures.