Congress recently passed the “One Big Beautiful Bill Act” (OBBB), a sweeping legislative package aimed at overhauling key aspects of tax, healthcare, and workplace policy.
The OBBB incudes significant updates to Health Savings Accounts (HSAs) and Flexible Spending Accounts (FSAs) aimed at expanding access, increasing savings flexibility, and modernizing tax-advantaged healthcare benefits. Most of these changes take effect beginning January 1, 2026, and will impact benefit planning for both employers and employees.
Key HSA Changes
Including All Bronze and Catastrophic Plans Available on Exchange as HDHPs
The OBBB automatically treats all Bronze and Catastrophic level plans that are available on the individual market through the Exchange as “HSA-qualified” coverage—even if those plan options would not otherwise meet the standard HDHP requirements.
First-Dollar Coverage for Telehealth Services
Telemedicine coverage can now be covered before the deductible without disqualifying the plan. This change is retroactive to plan years beginning after December 31, 2024.
Direct Primary Care (DPC) Compatibility
Individuals enrolled in DPC arrangements may now contribute to HSAs if paired with a qualifying HDHP. The OBBB also provides that DPC fees are a qualified medical expense that can be paid tax-free from an HSA.
Dependent Care FSA Increase
The annual contribution limit for dependent care FSAs will be increased to $7,500 per household (up from $5,000). This marks the first permanent increase since 1986. As always, please do not hesitate to reach out to your Marshall+Sterling Account Manager for more information.
Please note: The information contained above is for general informational purposes only and does not constitute legal advice.
