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The One Big Beautiful Bill Act, signed by President Donald Trump into law on July 4, 2025, contains several provisions that may impact an employer’s benefit plans. While the Act did not include any changes that directly affect retirement plans, other benefit plans may be affected. Many of these provisions take effect in 2026, and plan sponsors and executives should be aware of them. The following chart provides a brief summary of some of the changes made by the Act.

Topic

Description

Effective Date

Telehealth Coverage

Permanently allows high-deductible health plans to cover telehealth services before patients meet their deductibles.

Plan years beginning after 12/31/24

Bronze and catastrophic plan allowance in connection with HSAs

Bronze and catastrophic plans purchased through an exchange are now treated as high-deductible health plans, and individuals enrolled in these plans are eligible to contribute to a health savings account (HSA).

All months beginning after 12/31/25

Direct Primary Care Service Arrangements

Certain “direct primary care” arrangements are no longer considered disqualifying coverage as long as they are paired with a high-deductible health plan. This change allows contributions to an HSA if the individual is simultaneously covered by a high-deductible health plan and a direct primary care arrangement.

All months beginning after 12/31/25

Dependent Care Assistance Plan Limit Increase

Increased the benefit limit to $7,500 when filing as single or married filing jointly ($3,750 married filing separately).

Plan years beginning after 12/31/25

Exclusion for Employer Payments of Student Loans

Permanently allows employers to make student loan reimbursement payments.

All payments made after 12/31/25

Termination of Qualified Bicycle Commuting Reimbursement

Removes the exclusion for the qualified bicycle commuting reimbursement.

Tax years beginning after 12/31/25

Moving Expense Limitation Extension

Removes the exclusion for employer-provided qualified moving expense reimbursements (with few exceptions related to the military and intelligence communities) and the deduction for moving expenses.

Tax years beginning after 12/31/25

Deduction Limitation for Excessive Employee Remuneration

Code Section 162(m) limits the deduction for certain employees for remuneration above $1 million. Aggregation rules will now apply for purposes of the deduction limitation and the allocation of the deduction.

Tax years beginning after 12/31/25

Expansion of Excise Tax Application on Excess Compensation within Tax-Exempt Organizations

Code Section 4960 excise tax rules covering certain tax-exempt organizations that pay over $1 million in remuneration now apply with respect to any employee or former employee of the tax-exempt organization, not just certain covered employees.

Tax years beginning after 12/31/25

View Table

The above changes may have a significant impact on tax and employee benefit planning. As many of the provisions in the Act become effective within the next few months, it will be important to plan accordingly. Please contact us if you have any questions, or if you would like to discuss any potential plan design changes for your employee benefit plans.

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