Telehealth benefits for employers

For employers that offer an HSA-qualified HDHP, the tax rules for telehealth changed in an important and now permanent way.

What it is

In a group medical plan, telehealth is usually a covered benefit under the plan's terms: a visit with a plan-contracted or plan-designated clinician, with the copayment or other cost sharing the schedule lists. In a stand-alone benefit, the employer contracts with a vendor for a set of remote visits, sometimes for a per-employee-per-month fee, and employees use that service for eligible consultations.

Federal tax law now treats telehealth specially for HDHPs. Section 71306 of Public Law 119-21 (the act commonly called the One, Big, Beautiful Bill Act) made permanent a safe harbor that had begun as a temporary CARES Act rule. An HDHP may cover telehealth and other remote care services before the deductible and still be an HDHP. IRS Notice 2026-5 confirms that the permanent extension applies retroactively for plan years beginning after December 31, 2024.

Notice 2026-5 also states that the IRS will treat as telehealth, for this safe harbor, services on the list of telehealth services payable by Medicare that HHS publishes annually, and that for other services taxpayers should apply the principles of the Medicare telehealth rules. The safe harbor does not automatically extend to in-person services, medical equipment, or drugs furnished in connection with a remote visit, unless those items are themselves treated as telehealth under that guidance.

Who it fits

Telehealth is a fit for many groups, including companies with people in more than one location, multi-state teams, and employers who want a straightforward way for employees to reach a clinician for eligible visits. It is also a fit next to an HDHP, because the plan can now cover qualifying remote care before the deductible without putting HSA eligibility at risk under the safe harbor.

Direct primary care is a different design: a fixed periodic fee for a defined set of primary-care services, which may be delivered in person, remotely, or both. The two can appear in the same benefits conversation, but they are not the same product.

How it works for employers

We will first read how telehealth is already treated in the medical plan you are quoting — network, cost sharing, and whether it is available before the deductible. If you want a stand-alone telehealth benefit as well, we will describe the vendor's scope, hours, and how it coordinates with the medical plan, and we will put it on the same proposal as voluntary benefits or the medical plan.

For an HDHP, we will confirm that any pre-deductible remote-care benefit is designed to stay inside the Notice 2026-5 safe harbor, so the plan remains HSA-qualified.

Telehealth does not replace emergency care, and it does not, by itself, create a network of specialists or hospitals. Employees should still know how to use the medical plan for in-person and emergency services. For a multi-state workforce, we will check whether the plan's telehealth benefit is actually available in the states where people work and live, and how it is described in the summary of benefits. If you add a stand-alone vendor, we will also confirm how a visit is documented if the employee later has a related in-person claim under the medical plan.

How it compares

Plan-embedded telehealth is part of the medical benefit. A stand-alone telehealth benefit is an add-on, more like other ancillary coverage. Direct primary care is a membership-style primary-care arrangement with its own HSA rules. Each is a legitimate fit for some groups. We will not describe telehealth as a substitute for a medical plan or as a source of premium savings.