Permanent telehealth and direct primary care provisions expand 2027 plan design as the IRS raises deductible minimums and savings account limits
The minimum deductible for a high-deductible health plan (HDHP) rises to $1,750 for self-only coverage and $3,500 for family coverage in 2027, according to Revenue Procedure 2026-24. Plans sitting at the 2026 minimums of $1,700 and $3,400 need to move before January 1, or employees lose the ability to contribute to a health savings account (HSA).
The other thresholds move as well. The out-of-pocket maximum for an HDHP rises to $8,700 for self-only coverage and $17,400 for family coverage, and the HSA contribution limit rises to $4,500 and $9,000, up $100 and $250, according to Mercer's summary of the 2027 HSA and HDHP figures. The age 55 catch-up contribution stays at $1,000.
Telehealth made permanent
The One Big Beautiful Bill Act (OBBBA) made permanent the safe harbor that lets an HDHP cover telehealth before the deductible without disqualifying employees from HSA contributions, effective for plan years beginning after December 31, 2024, according to HUB International and Plante Moran. HUB advised employers to confirm that pre-deductible telehealth benefits align with the Medicare telehealth list.
Higher deductibles create a specific problem. An employee facing a $1,750 deductible has a reason to defer a routine visit, and first-dollar telehealth takes the deductible out of that decision for one category of care.
Direct primary care arrangements
The law also makes direct primary care service arrangements compatible with HSA contributions beginning in 2026. An employee can have a direct primary care membership and still contribute to an HSA, according to HUB International, provided the aggregate monthly fee stays within the caps: $150 for one person or $300 when the arrangement covers more than one person, according to Mercer. Both caps are unchanged for 2027.
Employers raising deductibles to manage costs are weighing these options against a hard budget. Marsh found that 59 percent of employers plan cost-cutting changes such as higher deductibles, and that costs would climb 11 percent in 2027 without action, according to HRD America's report on employer health costs rising 8.2 percent in 2027. A direct primary care membership paired with an HDHP keeps routine care outside the deductible while the major medical exposure stays behind it.
What to check before January 1
Three items need attention. First, the deductibles and out-of-pocket maximums of every HDHP offered for 2027 should meet the new limits, and plan documents and summary plan descriptions should reflect them. Second, open enrollment materials should state that pre-deductible telehealth does not affect HSA eligibility, since employees unsure of that may skip the benefit or the account.
Third, any direct primary care arrangement needs to stay within the fee caps and cover primary care only. The exception covers primary care, so an arrangement that adds other services may not qualify, and employers should confirm structure with counsel before relying on it.
