January 01, 2024

Business Group on Health Policy Position Statements

Business Group on Health’s position statements on health policy issues impacting employer-sponsored health coverage.

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Since their inception, health savings accounts (HSAs) paired with high-deductible health plans (HDHPs) have grown to play an important role in the plan designs offered by employers. According to Business Group on Health’s 2024 Large Employer Health Care Strategy Survey, 89% of surveyed Business Group members report offering an HSA/HDHP arrangement to employees, with HDHPs and PPOs now tied as the plan options with the highest enrollment. While the current HSA/HDHP design works for many, employers are also interested in certain HSA improvements and considering additional flexibilities to underlying coverage requirements.

As employers focus on providing high-quality, evidence-based benefits while lowering the overall cost of care, they have struggled with certain limitations of the HSA rules. Specifically, employers would like to cover certain evidence-based benefits such as chronic care management and certain preventive medications before employees satisfy their deductibles. Initially enacted during the COVID-19 public health emergency, and now extended for two additional years, HSAs paired with HDHPs can (but are not required to) cover all telehealth and other remote care services before participants satisfy deductibles from January 2020 through plan years beginning December 31, 2024.

Position

Additional flexibility in HSA rules would allow HSA/HDHP arrangements to deliver on the design’s underlying goals—more efficient health care purchasing and increased patient engagement in health care decisions. Specifically, we support:

Greater flexibility for pre-deductible coverages that have proven value, including:

• Permanently allowing plans to provide low/no-cost coverage of telehealth for primary care, mental health counseling, and similar services;
• Allowing plans to cover chronic condition management and medications;
• Allowing plans to cover onsite clinic services and other lower cost alternative sources of health care;
• Allowing plans to incorporate evidence-based benefit designs such as direct primary care and risk sharing models;
• Allowing plans to provide medical travel benefits with greater flexibility;

Improving access, supporting design innovation, and promoting consumer education and choice, including:

• Flexibility to adjust how deductibles apply to certain higher-cost items or services, such as those that involve copayment assistance or copayment waivers;
• Flexibility for Medicare-eligible employees to make HSA contributions; and
• Strengthening transparency in health care with usable price and quality metrics.

WHY IT MATTERS

• Rising health care costs continue to be a major concern for employers and employees.
• Permitting plan coverage of primary and preventive care and medications and services for management of chronic conditions prior to the deductible will prevent the need for more expensive care downstream.
• Coverage of primary care, mental health counseling, and other basic services offered through telehealth, onsite clinics, and other lower cost sites of care will help reduce health care costs for employers and employees.
• HSA funds, including employer contributions, help employees and their families afford their out-of-pocket health care expenses and save for future health care needs, including for retiree health expenses.

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