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You Make the Call - Dec. 23, 2025

Published:
By: NATP Staff
Telehealth coverage before meeting the deductible does not disqualify Jessica from contributing to an HSA for 2025 under updated IRS guidelines.

Question: In 2025, Jessica is covered by an HSA-eligible high-deductible health plan (HDHP). The plan also provides pre-deductible coverage for telehealth visits. Jessica is concerned that receiving telehealth benefits before meeting her deductible could make her ineligible to contribute to an HSA for 2025.  
 
Can Jessica still contribute to an HSA for 2025? 

Answer: Yes. Under Notice 2026-5, the One Big Beautiful Bill Act (OBBBA) made permanent (and retroactive for plan years beginning after Dec. 31, 2024) the safe harbor that allows an HDHP to provide telehealth and other remote care services on a pre-deductible basis without causing the plan to fail HDHP status. The IRS also confirms that an otherwise eligible individual may contribute to an HSA for 2025 even if, before OBBBA was enacted on July 4, 2025, the individual’s plan provided pre-deductible telehealth coverage, as long as the plan otherwise satisfied the requirements to be treated as an HDHP.  

Practical takeaway: 

If Jessica meets the other HSA eligibility rules (covered by an HDHP and no disqualifying coverage), pre-deductible telehealth coverage for the plan year beginning in 2025 does not, by itself, prevent HSA contributions. 

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"NATP team committed to supporting tax professionals with expert insights, industry updates, and resources, shown with green triangle design element representing the organization's brand.

NATP Staff

The NATP team is dedicated to supporting tax professionals with expert insights, industry updates, and resources that help them serve their clients with confidence.

Information included in this article is accurate as of the publication date. This post does not reflect tax law changes or IRS guidance that may have occurred after the publishing date.