New IRS Guidance on Health Savings Accounts Under OBBBA

The IRS has released new operational guidance regarding updates to health savings accounts (HSAs) under the One Big Beautiful Bill Act (OBBBA). This guidance elaborates on provisions established when the law was enacted, offering additional details on implementation to ensure regulatory compliance. Key updates include the permanent establishment of the telehealth safe harbor for individuals with high-deductible health plans (HDHPs) starting January 1, 2025. This initiative allows individuals to access telehealth services before meeting deductibles without impacting their HSA eligibility, enhancing payer-provider dynamics.

A pivotal aspect of the guidance is its specifications on Direct Primary Care Service Arrangements (DPCSAs) and their implications for HSA eligibility. Beginning in 2026, certain DPCSAs will enable individuals to continue making HSA contributions. Moreover, as of January 1, 2026, bronze and catastrophic health plans, whether obtained through health insurance exchanges or via health reimbursement arrangements, will now qualify as HDHPs compatible with HSAs. This adjustment addresses underwriting and risk management concerns, promoting broader access to compliant health plans amidst the evolving industry standards.

Stakeholders are invited to submit feedback on this guidance by March 6, 2026, potentially leading to further refinements. This feedback process exemplifies the evolving nature of regulatory compliance requirements within the insurance industry, particularly for insurers providing HDHPs. Engaging with stakeholders will ensure that carriers and providers adapt to these changes, facilitating a smoother transition and enhanced alignment with industry demands.