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Expanded HSA Opportunities and Employee Benefit Changes Taking Effect in 2026
Many employers and brokers are already evaluating plan design changes in anticipation of 2027 renewals and open enrollment periods. IRS Notice 2026-5 (PDF) details how the One, Big, Beautiful Bill Act (OB3) includes several changes to employee benefits that take effect in 2026. These provisions may influence how employers structure high-deductible health plans (HDHPs), Health Savings Accounts (HSAs), and telehealth benefits.
Key Changes
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Permanent Telehealth Relief for HSA-Compatible Plans. Prior pandemic-related relief allowed employers to offer telehealth services before an HDHP deductible was met without jeopardizing employees’ HSA eligibility. According to compliance summaries released for 2026 planning, this flexibility is now permanent.
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Expanded HSA Eligibility. The legislation also broadens circumstances under which individuals may contribute to an HSA. Compliance experts note that the changes create new opportunities involving: Direct Primary Care (DPC) arrangements, telehealth programs, and certain employer health benefit structures that previously created HSA eligibility concerns.
Industry observers are watching for future regulatory guidance surrounding fertility benefit offerings, healthcare transparency initiatives, and HIPAA privacy and cybersecurity requirements.
Tips for 2027 Open Enrollment Planning
- Review HDHP and HSA plan designs for 2027.
- Evaluate telehealth offerings.
- Confirm that employee communications explain HSA eligibility accurately.
- Monitor future IRS and Department of Labor guidance.
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