Telemedicine and HSAs

Who pays for the cost savings?

October 13, 2017

As health care costs continue to rise, so does the demand for cost-control strategies. One such strategy is telemedicine. Telemedicine is a service offered through many health insurance plans by which patients can consult with a doctor over the phone or through videoconference. Telemedicine doctors can often prescribe medication, thus eliminating the need for a trip to the doctor’s office. The trend has been gaining popularity in recent years and many anticipate continued improvements and evolutions of the service in the near future.

But how is telemedicine a cost-control strategy? Telemedicine can eliminate the need for visits to the emergency room, urgent care or the doctor’s office – which could save up to $6 billion annually by one estimate. Without the typical costs associated with in-person consultations such as rent, overhead, nursing staff, etc., telemedicine uses readily available technology to deliver consultations at a fraction of the cost.

How that reduced cost is paid, however, depends on the health plan offering telemedicine service. For a traditional preferred provider organization plan (PPO), co-pays are typically used to offset the cost of a doctor visit. Co-pays for telemedicine consultations would also be appropriate. The rules for high deductible health plans (HDHP), however, are very different.

A HDHP allows subscribers to contribute to a tax-advantaged health savings account (HSA). To be eligible to participate in an HSA, participants in a HDHP cannot receive any employer payment – directly or indirectly – for medical expenses before the deductible is satisfied. Indirect payments would include cost-sharing in the form of co-payments for consultations. The IRS has not directly addressed the issue of HSA eligibility and telemedicine. However, its guidance suggests that an employer offering a HDHP with an HSA and a telemedicine option should require the participants to pay fair market value of the telemedicine consultation. What is the fair market value of a telemedicine consultation? Who knows? It’s likely more than a co-pay but less than the network rate of a doctor’s office visit. Additional IRS guidance on this topic would be helpful, but until it’s issued, employers with HDHPs should be wary of “free” or co-pay telemedicine services.