Free Telehealth Restored Under HSA Until 2023

Free Telehealth Restored Under HSA Until 2023

Free Telehealth Restored Under HSA until 2023

Effective April 1, 2022, high-deductible health plans can once again offer first-dollar coverage for Telehealth and other remote services without making participants ineligible for health savings account (“HSA”) contributions.  The relief runs only through the end of 2022. This relief allows individuals with High Deductible Health Plans  (“HDHPs”) to receive free telehealth services prior to the satisfaction of their minimum deductible and remain eligible to make Health Savings Account (“HSA”) contributions.


Individuals may contribute to an HSA if they are covered by a qualifying HDHP and do not have other disqualifying coverage. Generally, telehealth or other remote health care services are considered other health care coverage that, if provided before satisfaction of the required deductible, may be disqualifying for purposes of contributing to an HSA. 

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) were signed into law on March 27, 2020. Among other things, the CARES Act offered temporary relief related to telehealth and other remote care services when offered with an HDHP and HSA. Specifically, for plan years beginning on or before December 31, 2021, telehealth and other remote care services could be offered before satisfaction of the deductible without jeopardizing an individual’s eligibility to contribute to an HSA.

Employer Action

Employers offering HDHPs with HSAs should consider whether to re-implement (or continue) free telehealth as part of a benefit offering. Employers with calendar year plans may 

have already re-introduced a cost associated with telehealth for HDHP/HSA participants once the CARES Act relief expired and should consider whether to waive those costs again given the temporary nature of this relief. Additionally,  employers with non-calendar year plans should consider the administrative and communication burdens that may be imposed by providing relief that may expire prior to the end of the current plan year. 

It is important that employers review these changes with their carriers, Third Party Administrators and telehealth vendors to understand their approach and communicate any changes with participants.

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Employee Retention Tax Credit

Employee Retention Tax Credit

Employee Retention Tax Credits under CARES ACT have been available yet there has been confusion surrounding this. Employee Retention Tax Credits (ERTC). Much of this has been covered under Corona Virus Resource Page –What the Coronavirus Means for Your Business.   The ERTC was extended and modified by the Consolidated Appropriations Act of 2021. 

COVID-19 Employee Retention Credit available for Businesses Financially Impacted

The Treasury Department and the Internal Revenue Service today launched the Employee Retention Credit, designed to encourage businesses to keep employees on their payroll. The refundable tax credit is 50% of up to $10,000 in wages paid by an eligible employer whose business has been financially impacted by COVID-19.


Does my business qualify to receive the Employee Retention Credit?

The credit is available to all employers regardless of size, including tax-exempt organizations. There are only two exceptions: State and local governments and their instrumentalities and small businesses who take small business loans.

Qualifying employers must fall into one of two categories:

1.The employer’s business is fully or partially suspended by government order due to COVID-19 during the calendar quarter.

2. The employer’s gross receipts are below 50% of the comparable quarter in 2019. Once the employer’s gross receipts go above 80% of a comparable quarter in 2019, they no longer qualify after the end of that quarter.

How is the credit calculated?

The amount of the credit is 50% of qualifying wages paid up to $10,000 in total. Wages paid after March 12, 2020, and before Jan. 1, 2021, are eligible for the credit. Wages taken into account are not limited to cash payments, but also include a portion of the cost of employer-provided health care.

How do I know which wages qualify?

Qualifying wages are based on the average number of a business’s employees in 2019.Employers with less than 100 employees: If the employer had 100 or fewer employees on average in 2019, the credit is based on wages paid to all employees, regardless if they worked or not. If the employees worked full time and were paid for full-time work, the employer still receives the credit.

Employers with more than 100 employees: If the employer had more than 100 employees on average in 2019, then the credit is allowed only for wages paid to employees who did not work during the calendar quarter.

I am an eligible employer. How do I receive my credit?

Employers can be immediately reimbursed for the credit by reducing their required deposits of payroll taxes that have been withheld from employees’ wages by the amount of the credit.

Eligible employers will report their total qualified wages and the related health insurance costs for each quarter on their quarterly employment tax returns or Form 941 beginning with the second quarter. If the employer’s employment tax deposits are not sufficient to cover the credit, the employer may receive an advance payment from the IRS by submitting Form 7200, Advance Payment of Employer Credits Due to COVID-19.

Eligible employers can also request an advance of the Employee Retention Credit by submitting Form 7200.

Where can I find more information on the Employer Retention Credit and other COVID-19 economic relief efforts?

Updates on the implementation of this Employee Retention Credit, Frequently Asked Questions on Tax Credits for Required Paid Leave and other information can be found on the Coronavirus page of

Do you have a Checklist for the Paycheck Protection Loans Documentations?

Start preparing NOW. Gather documents that provide proof of payment for allowable expenses under the Paycheck Protection Program and be ready to make related certifications for the application.

I’m working with a PEO, how do I get these forms to the IRS?

When partnering with a PEO, the PEO may request an attestation from the client or the client‘s CPA  certifying that the client qualifies for the ERTC.  This is because the PEO is unable to verify that the client incurred a reduction in gross receipts or otherwise qualified for the credit.  Furthermore, indemnification may be requestedgiven that incongruities with claiming the credit must be reconciled on the PEOs Form 941.  Finally, in order to prevent multiple filings, it is possible that a PEO may establish deadlines for clients claiming the ERTC and impose an administrative fee associated with processing the ERTC for former clients or clients seeking to claim the credit outside of specified time frames.

For more information about the ERTC, please contact your PEO service provider.

Paycheck Protection Program Document Checklist and Certifications


ERTC Video Explainer

Silver Linings Pandemic Playbook  – American Benefits Council


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For more information on PEOs or a customized quote please submit your contact. We will be in touch ASAP.