Use the Telemed Safe Harbor While it Lasts 

As I’ve worked with employers over the past few weeks on their 2021 planning, one topic keeps coming up: what to do about the IRS telehealth safe harbor that allows participants in high-deductible health plans with HSAs to receive telemedicine with no or low co-pays without the usual deductible requirement? For calendar year plans, the IRS now permits the waiver through the end of 2021 without jeopardizing the HSA eligibility of the participant. Some employers are on the fence about how to handle their telehealth plan design for now, knowing that they will not have design flexibility once the waiver comes to an end.

Since the outset of the pandemic, we’ve seen increased utilization of telehealth services and, importantly, an increase in first-time users – and not just for COVID-19 related items. There’s been a huge shift among providers as well, as many were thrust into using virtual technology. This exposure to virtual healthcare has propelled us more quickly into the future we have been trying to get to for years. Now is the time for employers to take a thoughtful pause to determine how their plan design needs to change to take advantage of this new environment. 

In my opinion, this is a good opportunity to encourage plan members to try telehealth. Mercer survey data shows, not surprisingly, that telemedicine utilization is higher when it’s offered for free or at a low co-pay. Even if you have to end the waiver for HDHP participants in 2022, that’s enough time for employees to learn positive new health care behaviors, and to reinforce them. Some employers are planning to openly communicate to their employees that the cost share provision may need to be adjusted in the future in accordance with IRS regulations. Oliver Wyman survey data has shown that once someone tries telehealth they are more likely to use it again. Take advantage of this point in time to get your employees comfortable with telehealth – it will do a lot to change when and how they access care. As you consider various design options, be sure that you’re looking holistically at your strategy, including a broader look at how you can leverage technology and virtual tools to drive cost efficiency and a better member experience.