The following provisions in the OBBBA will (a) allow plans to offer pre-deductible telehealth coverage and still be HSA-qualified, (b) classify all individual market bronze and catastrophic plans as HSA-qualified, and (c) classify direct primary care (DPC) arrangements as HSA qualified medical expenses. This guide lists the provisions in order of effective date and discusses how Minnesota will be uniquely impacted by each.
HSAs are tax-advantaged savings and investment accounts that people can use to pay for qualified medical expenses (QMEs).
Effective Date: July 4, 2024
Background
Historically, individuals could only contribute to an HSA if they were actively enrolled in a qualified high-deductible health plan (HDHP). One requirement of qualified HDHPs was that they could not offer pre-deductible coverage beyond that for preventive services.
The OBBBA permits qualified HDHPs to offer pre-deductible coverage not only for preventive services, but also for telehealth services.
Impact in Minnesota
Insurers that sell HDHPs, may modify their benefits to reflect the newly allowed pre-deductible coverage for telehealth services. If such plans are sold, it may reduce the rate at which Minnesotans with HDHPs delay or forgo telehealth care due to cost.
Effective Date: January 1, 2026
Background
Historically, individuals could only contribute to an HSA if they were actively enrolled in a qualified high-deductible health plan (HDHP). The two most prominent requirements for HSA-qualified HDHPs were (1) a minimum deductible, as determined by the Internal Revenue Service on an annual basis, and (2) the omission of any pre-deductible coverage beyond that for preventive services. These requirements did not align perfectly with metal tier (i.e., actuarial value) classifications on the individual market (e.g., some bronze plans were HSA-qualified, and some were not).
The OBBBA classifies all bronze and catastrophic plans on the individual market as HSA-eligible HDHPs.
Impact in Minnesota
Minnesotans who (a) seek coverage on MNsure and (b) want to contribute to an HSA will be able to do so in a less complicated way.
Effective Date: January 1, 2026
Background
Direct primary care arrangements (DPCs) are contracts through which individual patients directly pay primary care providers for a defined set of primary care services for a set fee over a specified period of time. Historically, individuals actively enrolled in DPCs have not been eligible to contribute to HSAs, and individuals with HSAs have not been allowed to use their HSA funds on DPCs.
The OBBBA removes both these restrictions for DPCs that (a) do not exceed $150 per month per individual or $300 per month per family and (b) exclude services that require general anesthesia, prescription drugs (except vaccines), and lab services.
Impact in Minnesota
Minnesotans who want to contribute to HSAs while enrolled in DPCs and/or use HSA funds on DPCs will have the freedom to do so. In the wake of this provision, the demand for DPCs in Minnesota might increase, and Minnesota physicians interested in providing DPC product lines may see greater interest.