Although the original House of Representatives version provided for extensive health care changes and pharmacy benefit manager (PBM) reforms, the final of the One Big Beautiful Bill Act (OBBB) contains only a few provisions that affect employee benefit plans. Nonetheless, the OBBB offers a few useful options for benefit plan sponsors.

High-deductible health plan (HDHP) enhancements

Telehealth relief for HDHPs made permanent. The CARES Act of 2020 created a temporary safe harbor allowing HDHPs to provide telehealth services to participants before their annual deductibles were met, without jeopardizing HSA contribution eligibility. The relief was further extended by the Consolidated Appropriations Act of 2024, but only through December 31, 2024. The OBBB makes the relief for HDHP telehealth services permanent and retroactive to January 1, 2024, closing the compliance gap with the prior relief. As a result, employers that offer HDHPs should consider taking action to amend their plans to permit first-dollar telehealth benefits.
Fees for direct primary care service arrangements are HSA eligible. The OBBB creates an exception from the HDHP first-dollar rules for the payment of monthly fees for "direct primary care service" arrangements (DPCs). DPCs typically involve patients paying monthly membership fees to primary-care providers covering office visits, preventive care, and routine labs. Effective January 1, 2026, the OBBB permits HDHP participants to use their HSAs to pay these monthly DPC fees. The exception for DPC fees is limited to $150 per month for an individual participant or $300 per month for families, and these limits are indexed for inflation annually after 2026. Employers that offer HDHPs should consider amending their plans to accommodate DPC fees for the 2026 plan year.

Increased dependent care flexible spending account (FSA) limits

Effective for tax years beginning in 2026, the annual dependent care FSA limit is increased to $7,500 per individual or married couple ($3,750 for married couples filing separately). The increased limit is not indexed for inflation for years after 2026.

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A look at the limited employee benefits provisions of the One Big Beautiful Bill Act

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