The One, Big, Beautiful Bill (OBBB), signed into law on July 4, 2025, introduces several changes to employee benefit plans. Employers have a unique chance to not only stay ahead of compliance requirements but also to strategically enhance their welfare benefit offerings to their workforce. It’s critical to understand the nuances of the OBBB and explore strategies for implementation that will help unlock meaningful advantages for your workforce while positioning your organization for long-term success.
Direct primary care & HSA compatibility
Starting Jan. 1, 2026, the OBBB allows individuals with direct primary care (DPC) arrangements to contribute to Health Savings Accounts (HSAs) if their monthly fees are $150 or less ($300 or less for families), with these limits adjusted annually for inflation. DPC is a healthcare model where patients pay a fixed fee directly to their primary care doctor for services like checkups, preventive care, and chronic condition management.
As the number of independent primary care providers decreases, employers may want to consider how DPC fits within a broader benefits strategy. DPC memberships can help address appointment availability, improving doctor/patient relationships, unnecessary steerage to specialists and/or facilities, and prescription drug spend. Pairing a DPC membership and an HSA-eligible high-deductible health plan also presents more opportunity for patients to receive low/no cost care without jeopardizing HSA eligibility.
Telehealth coverage under HDHPs
One of the key provisions of the OBBB is the permanent return of the telehealth safe harbor for High Deductible Health Plans (HDHPs). This allows HDHPs to waive deductibles for telehealth services without disqualifying enrollees from contributing to a Health Savings Account (HSA). This change is retroactive to Dec. 31, 2024, providing plan sponsors with flexibility in implementing the change either midyear or at the start of the next plan year.
The telehealth safe harbor for HDHPs was introduced during the COVID-19 pandemic. This safe harbor allows plans to fully or partially cover telehealth services without running afoul of the first-dollar coverage provision associated with HSA eligibility. Employers should review current plans and/or carved-out telehealth arrangements to determine preferred coverage provisions. If desired, this safe harbor will allow employers to treat HDHPs and traditional plans the same as it relates to telehealth coverage.
Dependent Care FSA limit increase
Effective Jan. 1, 2026, the OBBB increases the maximum contribution limit for dependent care Flexible Spending Accounts (FSAs) from $5,000 to $7,500 for single individuals and married couples filing jointly. This change allows employees to allocate more funds toward dependent care expenses on a tax-free basis.
The Dependent Care FSA limits haven’t been increased since 1986, even though childcare and other dependent care costs have increased considerably over that same period. Employers aren’t required to increase the Dependent Care FSA limit; however, this limit increase does present a clear tax advantage. Employers should consider current Dependent Care FSA utilization and the fact that nondiscrimination rules will still apply.
Unlocking competitive advantages through OBBB
Those who act thoughtfully won’t only fulfill evolving legal expectations but also cultivate a competitive edge by offering benefits that resonate with and support today’s workforce. To learn more about how you can position your business to attract, retain, and empower your employees for years to come, please contact your Plante Moran advisor.
