In July 2025, the One Big Beautiful Bill Act permanently amended Section 223 of the Internal Revenue Code, making the telehealth safe harbor for high deductible health plans permanent, retroactive to plan years beginning after December 31, 2024. That means high deductible health plans can now offer virtual care and remote chronic condition management at no cost to the member before the deductible is met, without putting HSA eligibility at risk, and that permission is no longer temporary or subject to renewal each year.
Most employers haven't updated how they think about their HDHP to reflect that. The plan is still discussed the way it was discussed five years ago: as the option that shifts cost to employees in exchange for a lower premium. That description is increasingly out of date, and the gap between what's now possible and what most benefits strategies actually do with it is worth closing.
The standard explanation for why employees avoid care under a high deductible plan is that the number itself is intimidating. :
Employees don't avoid care because of the deductible number sitting somewhere down the road. They avoid it because there's no $0 option before that point, so today's visit costs money they'd rather not spend on something that might not be serious. A minor issue goes unaddressed for weeks, sometimes months, and by the time it's finally treated, it's often no longer minor.
Give that same employee a $0 virtual visit that happens in minutes, and the calculation changes completely. Care gets sought early because there's no cost barrier at the moment it matters. Notably, a meaningful share of the patients who use a service like this are new to primary care altogether, which suggests this isn't just changing when existing patients seek care, it's bringing in people who were avoiding the system entirely.
WATCH: One Solution, Many Strategies: Virtual Care Across the Benefits Ecosystem
For employees using their HSA as a long-term investment vehicle rather than a spending account, unlimited $0 access to the 80 to 90 percent of routine care that virtual primary care can handle means those HSA dollars stay untouched for the things they were actually meant to cover: major medical events, or retirement.
That's a real repositioning of what an HDHP is. Not the cheap plan that trades cost for coverage. The plan with a savings mechanism built into it, one that only works as intended when routine care isn't quietly draining the account it was supposed to be protecting.
HDHPs have a well-documented weakness with chronic disease compliance, and it compounds the point solution problem employers are already navigating elsewhere in their strategy. Prescriptions and the frequent check-ins that chronic conditions require are expensive before the deductible is met, so adherence slips. A patient managing diabetes or hypertension who skips refills or check-ins because of pre-deductible cost isn't saving money. They're deferring a much larger claim.
Pair that with the fragmentation most employers are already dealing with across their point solution stack, and an HDHP without a strong virtual primary care front door has two compounding weaknesses instead of one. Close the access gap with unlimited, no-cost virtual visits, and adherence improves because the friction that was causing patients to defer care disappears. That stabilizes the long tail of chronic claims that otherwise erode an HDHP's cost advantage over time.
There's a geographic dimension worth a brief mention. HDHPs often expose network gaps for employees who don't live near an in-network provider, particularly in rural areas. The alternative, an out-of-network urgent care visit or an ER trip that counts fully against the deductible, is exactly the outcome a well-designed benefits strategy is trying to avoid. A $0 virtual option removes that bind entirely, and for an employer trying to maintain a consistent benefits experience across a distributed workforce, that consistency is worth more than it might initially look like on a spreadsheet.
None of this is a case for switching plan designs. We’re presenting a case for looking closely at what the HDHP most employers already offer can now do, now that the regulatory landscape has finally caught up with what virtual care makes possible.
Give that plan the right front door and it becomes the design doing the most with the least friction of any funding structure on the table. That capability has been available since the rule change made it permanent. Employers are taking notice and taking action.
If your HDHP doesn't have that front door yet, the rule change already did the hard part. Talk to our team about what adding it could look like for your plan