On December 9, Treasury and the IRS released Notice 2025-119, guidance that summarizes the health savings account (HSA) expansions enacted in last summer’s tax and spending cuts reconciliation law. In Q&A form, the guidance clarifies what the terms mean and how the rules work.

The Notice begins with a summary of the expansions to HSA programs that Congress enacted into law last July. Generally, the new HSA law qualifies Affordable Care Act (ACA) exchange-based bronze and catastrophic (also called copper) plans as high-deductible health plans (HDHPs). The new law also qualifies direct primary care service arrangements (DPCSAs) as HDHPs. That allows purchasers of bronze and catastrophic plans and participants in a DPCSA to have an HSA. In addition, the new law allows plans to provide telehealth and other remote health care services before meeting their HDHP deductible.

After the summary of the expansions, the Notice goes on to provide 20 questions and answers on how these expansion provisions work. For example, in one Q&A, the guidance makes clear that the HSA expansions apply to individual (not employer-provided) coverage, and also that a bronze or catastrophic plan can be purchased in the private market (i.e., purchase from an exchange is not required).

Prospects: IRS and Treasury request comments on the Notice by March 6, 2026. The Notice specifies that late comments will be considered only if they do not delay issuance of additional guidance.

NAIFA Staff Contact: Jayne Fitzgerald – Director – Government Relations, at jfitzgerald@naifa.org