Unwritten Rules in Healthcare Benefits | Concierge TPA

As has been widely reported, HR1, commonly referred to as the One Big Beautiful Bill (OBBB), recently passed Congress and was signed into law on July 4, 2025. While much of the coverage has focused on its tax provisions, the OBBB’s changes include improvements to Health Savings Accounts (HSAs), permanent extension of the telehealth relief for high-deductible plans (HDHPs), and an increase in the annual contribution limit for dependent care Flexible Spending Accounts (FSAs). For your convenience, we’ve outlined them below.

Dependent Care Flexible Spending Accounts (FSAs)

The dependent care FSA limit has been increased. For plan years starting on or after January 1, 2026, the new dependent care FSA limit will increase to $7,500.00/year (or $3,750.00 for married couples who file taxes separately). Unfortunately, this new limit is not indexed for inflation.

Health Savings Accounts (HSAs)

The legislation calls for long-awaited expanded eligibility for HSAs including:

• Favorable Treatment for Coverage Under Direct Primary Care Service Arrangements (DPCSA) – This provision would permit HSA-eligible individuals enrolled in DPCSAs to make or receive HSA contributions and allow individuals to use HSA funds to pay for certain DPCSA services. A DPCSA is medical care by primary care practitioners in exchange for a fixed periodic fee of no more than $150.00 per month, per employee ($300.00 if multiple individuals are covered). Additionally, fees paid under a DPCSA are treated as medical expenses and thus exempt for the prohibition that HSAs cannot pay for insurance.

ACA Eligibility Expansion

For those shopping for plans on the ACA Marketplace, this provision requires that HSAs will treat bronze and catastrophic plans as high-deductible health plans. As HDHPs, participants in such plans now qualify for HSA plans.

Permanent Relief for Telehealth Services Covered by HSA

Retroactively restores to January 1, 2025, and permanently allows:

• HSA-qualifying HDHPs to cover telehealth services on a pre- or no-deductible basis and
• An otherwise HSA-eligible individual to receive pre- or no-deductible coverage for telehealth services from a vendor outside of the HDHP.

In both instances, the pre- or no-deductible telehealth coverage won’t interfere with an individual’s eligibility to make or receive HSA contributions.

Employer Next Steps

Given all the changes in the OBBB, employers should take the following steps to drive future growth and manage costs:

• Enhance compliance systems: Update your systems and prepare to support new health benefit requirements.
• Update benefits communication: Reflect changes to FSAs and HSAs.
• Monitor healthcare costs: Understand how coverage shifts may affect your plan offerings.
• Watch for Guidance from the IRS: Look for future alerts from the IRS regarding implementation rules and clarifications.

Effective Dates

All the provisions go into effect on January 1, 2026.

Helpful Resources

• Full text of HR 1 Text - H.R.1 - 119th Congress (2025-2026): One Big Beautiful Bill Act | Congress.gov
• Congressional Budget Office Analysis: Information Concerning the Budgetary Effects of H.R. 1, as Passed by the Senate on July 1, 2025 | Congressional Budget Office
• KFF HSA Chart: Tracking the Health Savings Accounts Provisions in the 2025 Reconciliation Bill | KFF