One Big Beautiful Bill Act

On July 4, 2025, the final version of the One Big Beautiful Bill Act was signed into law. See below a summary of the key sections of the bill that impact consumer-directed benefits.

Telehealth Safe Harbor for HSAs (Section 71306) – Effective 1/1/2025 (retroactively)
This bill permanently reinstates the safe harbor allowing high-deductible health plans (HDHPs) to cover telehealth services without requiring a deductible (or with a deductible below the statutory threshold) while still maintaining HDHP status for Health Savings Account (HSA) eligibility. This provision applies retroactively.

HSAs and Bronze/Catastrophic Plans (Section 71307) – Effective 1/1/2026
This bill allows any bronze or catastrophic health plan offered through the Exchange will qualify as a high-deductible health plan for HSA purposes.

Direct Primary Care Service Arrangements (Section 71308) – Effective 1/1/2026
This bill allows individuals to participate in a direct primary care service arrangement without disqualifying them from contributing to an HSA. These arrangements will not be considered a health plan, and associated fees are treated as qualified medical expenses. To qualify under these rules, a direct primary care service arrangement must provide primary care services by primary care practitioners for a fixed monthly fee, capped at $150 for individuals and $300 for families, with future adjustments for inflation. Services that may be considered “primary care” for other applications, but are not included in these new rules, are:

    • Procedures requiring general anesthesia
    • Prescription drugs (except vaccines)
    • Lab services not typically administered in an ambulatory setting

Dependent Care FSA Contribution Limits (Section 70404) – Effective 1/1/2026
Starting in 2026, the maximum contribution to dependent care assistance programs will increase to $7,500 per household (up from $5,000), and to $3,750 (up from $2,500) for married individuals filing separately.

Qualified Transportation Fringe Benefits (Section 70112) – Effective 1/1/2026
The exclusion for bicycle commuting reimbursements is eliminated. Additionally, the inflation adjustment used to determine the annual limit for all qualified transportation fringe benefits is changed.