On December 9, 2025, the IRS released IRS Notice 2026-5, which offers guidance regarding modifications to HSAs instituted by the One, Big, Beautiful Bill Act (OBBBA), enacted on July 4, 2025. These changes involve telehealth services, bronze and catastrophic plans, and direct primary care service arrangements (DPCSAs).
Telehealth Services
The OBBBA permanently allows group health plans to offer telehealth services to HDHP participants before deductibles are met, without affecting HS