Is Recent Legislation a First Step to "Decoupling" HSAs from Rigid Designs?
By William G. Stuart | Originally posted on Health Savings Academy
The One Big, Beautiful Bill Act offers a second path to creating an HSA-qualified plan. How will it affect coverage in the future?
The One Big, Beautiful Bill Act, symbolically signed July 4 by President Trump, contains many important and controversial changes in federal fiscal policy. One important healthcare provision defines all Bronze and Catastrophic coverage available on federal- and state-facilitated insurance marketplaces as HSA-qualified plans.
How will this change affect the nongroup market? Will it mean more or fewer HSA-qualified options in public marketplaces? What is decoupling? Is this approach to decoupling justified?
Let's dive into these questions.
Prescriptive Plan Design
Section 223 of the federal tax code outlines the rigid design requirements for an HSA-qualified plan:
A statutory minimum annual deductible ($1,650 for self-only coverage and $3,300 for a family plan in 2025, increasing to $1,700 and $3,400 in 2026).
All services except select preventive care and telemedicine are subject to the deductible.
A statutory out-of-pocket maximum for covered in-network services ($8,300 and $16,600 in 2025, rising to $8,500 and $17,000 in 2026).
No member's out-of-pocket maximum for in-network covered services can exceed the federal limit of $9,200 in 2025 ($10,200 in 2026).
The shortcoming of this approach is that it does not distinguish between high-value and low-value care, nor does it allow for flexibility to respond to a patient's or employee population's most pressing medical conditions. For example, an employer cannot cover chiropractic care below the deductible for its warehouse staff, nor can a company that has identified sleep deprivation as a serious issue among its workers offer complimentary consultations with visiting onsite sleep doctors and split the cost of a CPAP machine with employees with a diagnosis of sleep apnea.