If you offer both an HSA-qualifying high-deductible health plan (HDHP) and an onsite (or near site) health clinic – or would like to – here’s a bit of good news. Recent IRS guidance (Notice 2019-45) identifies a new limited set of preventive care services, items and prescription drugs for individuals with chronic conditions that HSA- qualifying HDHPs may provide on a low- or no-deductible basis without jeopardizing an individual’s eligibility to make or receive tax-free HSA contributions.
The benefit for an onsite clinic sponsor (and employees with access to a clinic) is that the onsite clinic can provide IRS specified services and medications used to treat certain chronic conditions such as diabetes and asthma, before the member has met their HDHP deductible. This provides you with some flexibility to cover more of the upfront costs, which may influence an employee's decision to utilize the clinic. And yes, this is what you want.
Still, employers who sponsor onsite health clinics are looking for more flexibility to offer first-dollar clinic access to HDHP members. The Health Savings Act (S 12) introduced by Senator Marco Rubio (R-FL) would, among many other things, permit pre-deductible use of onsite medical clinics for certain services without risking HSA eligibility. Currently, many employers charge a fair market value for certain services to ensure individual’s HSA-eligibility remains intact. This charge has the unintended consequence of disincentivizing employees from more easily obtaining the primary care that they may need.
According to our most recent 2018 Worksite Clinic Survey, worksite clinics are a growing trend. One-third of all organizations surveyed with 5,000 or more employees, provide a general medical clinic at or near the worksite. That’s up from 24% in 2012. Half of survey respondents that offer an HSA-qualifying HDHP believe that charging members with HSAs fair-market value for clinic services before their HDHP deductible is met has reduced clinic utilization.
So if you offer an, onsite (or near-site) clinic to your employees and charge for non-preventative services, it’s time to revisit your clinic fee structure to see if certain changes can be made in light of recent IRS guidance to remove barriers to chronic care.