Telemedicine is becoming a popular method of providing a variety of medical services. Employers that offer high deductible health plans (HDHPs) that are compatible with health savings accounts (HSAs) should consider how a telemedicine benefit may impact participants’ HSA eligibility.

The IRS has not addressed how telemedicine benefits impact individuals’ eligibility for HSA contributions. Under the IRS’ general rules for HSA eligibility, a telemedicine program may not prevent an individual from contributing to an HSA if the program satisfies one of the design options described below:

• The telemedicine program is offered as part of the HDHP and the program’s benefits are subject to the HDHP deductible (with the exception of preventive care benefits).
• The telemedicine program is not considered a “health plan” under the HSA eligibility rules because it does not provide significant benefits for medical care or treatment.
• Benefits under the telemedicine program are limited to preventive care services.

Please refer to the attached Compliance Overview and contact your NEEBCo representative with any questions you may have.

Telemedicine Impact on HSA Eligibility