Question of the Day: Consolidated Appropriations Act of 2023

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Q: Did the Consolidated Appropriations Act (CAA) of 2023, signed on December 29, 2022, include any changes to health plans?

A: The Consolidated Appropriations Act of 2023 included a provision in Sec 4151 to extend the ability for Qualified High Deductible Health Plans (QHDHP) to provide first-dollar coverage for telehealth or other remote care services before plan deductibles are met. The temporary extension will not jeopardize Health Savings Account (HSA) eligibility. The extension applies for plan years beginning after December 31, 2022, and before January 1, 2025. It is optional for health plans to make this change.

Q. If we covered telehealth without deductible previously under the prior legislation, how does this new legislation impact my group health plan?

A: The permission under the spending bill expired on 12/31/2022. The new legislation under the CAA is effective for the first day of your plan year in 2023. Therefore, non-calendar year plans may have to manage through a gap between the end of 2022 and the beginning of their non-calendar year plan, where this provision could be applied again.

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