On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), a sweeping budget reconciliation measure with far-reaching implications for employer-sponsored benefit plans. Several key provisions—ranging from expanded HSA rules to DCAP increases—are directly relevant for HR and benefits leaders managing plan design, compliance, and workforce wellness strategy. Here’s what your organization needs to know.
Telehealth Permanently Protected for HSA Plans
Effective Plan Years Starting in 2025
After years of temporary relief, employers can now offer telehealth and remote care services with no cost-sharing—without compromising employees’ HSA eligibility. This change, made permanent by OBBBA, retroactively applies to the start of the 2025 plan year and provides long-term flexibility for plan design.
Employers can maintain zero-cost telehealth access under HDHPs.
Supports virtual-first or hybrid care strategies without HSA disruption.
Direct Primary Care (DPC) + HSAs: A New Era Begins in 2026
Starting in 2026, employers may integrate Direct Primary Care arrangements into their benefit strategy without disqualifying employees from HSA contributions, as long as these arrangements meet specific requirements:
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Fixed Monthly Fees: No more than $150/month for individuals or $300/month for families (indexed annually).
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Primary Care Focus: Services must be limited to typical ambulatory primary care. High-complexity procedures, most prescription drugs, and advanced labs are excluded.
New HSA-Eligible Expense: DPC fees can now be reimbursed through HSA funds.
This opens the door for innovative, personalized, and preventive care models within employer HDHP offerings.
Marketplace Plan Eligibility for HSAs Expands in 2026
Another major HSA-related shift: Bronze and catastrophic Marketplace plans will now qualify as high-deductible health plans (HDHPs) starting in 2026—even if they don’t meet traditional HDHP design standards.
Impact to Employers:
This change primarily affects employers offering ICHRA or QSEHRA models, as individual plan selection via the Marketplace becomes a more HSA-friendly option.
Student Loan Repayment: Tax-Favored Treatment Made Permanent
The OBBBA extends the CARES Act’s student loan relief by making employer-sponsored student loan repayment programs a permanent feature of §127 educational assistance.
Effective Beyond 2025:
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Employers may continue offering up to $5,250/year tax-free toward employee student loans.
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This limit will now be indexed annually for inflation.
A compelling tool for attracting and retaining talent—especially younger professionals burdened by education debt.
Dependent Care FSA Limits Increased for First Time in Decades
Effective 2026, the maximum reimbursement under Dependent Care Assistance Programs (DCAPs) increases to:
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$7,500/year (previously $5,000)
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$3,750/year for married individuals filing separately
Not indexed for inflation—this limit will remain static until Congress acts again.
Employers should communicate this expanded benefit during open enrollment and reevaluate FSA contribution strategies for impacted employees.
Transportation Fringe Benefits Adjusted (and One Repealed)
Two key updates to qualified transportation plans under IRC §132, effective 2026:
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Bicycle Commuting Reimbursement Eliminated: The tax-free reimbursement of bike-related commuting costs is permanently removed.
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Annual Inflation Adjustments Updated: The method for determining annual increases to transportation benefit limits (e.g., parking and transit) is now revised.
These changes will impact fringe benefit planning for organizations with large commuter populations.
Action Items for Employers
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Review and revise HDHP designs to incorporate telehealth and, potentially, direct primary care in line with HSA rules.
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Communicate updates around increased DCAP limits and student loan assistance to your workforce ahead of open enrollment.
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Prepare for 2026: Model ICHRA offerings using Marketplace bronze/catastrophic plans, and audit transportation benefits for compliance.
Ethos Benefits is here to help you navigate and operationalize these changes—so your benefit strategies stay compliant, competitive, and aligned with employee needs.
