Benefitfocus Analyzes HDHP-HSA Plan Trends In the 2025 State of Employee Benefits Report

State of Employee Benefits Report & HDHP-HSA Plan Trends 

Each year, Benefitfocus takes a deep dive into its customer enrollment transactions and its continued monitoring of trends in the employee benefits ecosystem to provide you with insights on the current state of the benefits industry and where the industry is heading. 

One interesting trend identified in Benefitfocus’ 2025 Report is the selection of a “traditional health plan” (i.e., a PPO or EPO with a relatively low deductible) as compared to the selection of a High-Deductible Health Plan (HDHP) that can be paired with a Health Savings Account (HSA) (i.e., an “HSA-eligible HDHP”). 

In particular, Benefitfocus found that Gen Z workers had the highest HSA-eligible HDHP participation relative to Millennials, Gen Xers, and Baby Boomers, and while overall participation in HDHP plans dipped slightly across all generations in 2025, Benefitfocus’ data showed that HSA-eligible HDHP participation increased among Gen Zers at a greater clip compared to Millennials, Gen Xers, and Baby Boomers from 2024 to 2025. 

Benefitfocus also found that Gen Z workers had the lowest health care utilization. This makes some sense considering the fact that Gen Z are younger, and it’s likely that the younger you are, the less health care you may need to utilize. 

However, Benefitfocus suggests that Gen Zers are under-utilizing health care because there is a gap in understanding (1) the benefits that are available to them, and also, (2) the various engagement tools that can help them access these benefits. 

To this latter point, there are various tools and different programs that employers can deploy (1) to “engage” Gen Zers and (2) to better help Gen Zers understand that accessing high-value, cost-effective health care services (like preventive care, Telehealth services, and also Direct Primary Care services) is available to them for both short-term and long-term health needs. 

Recent Changes to the Law May Increase HSA-Eligible HDHP Enrollment 

Congress just passed – and President Trump just signed into law – the Reconciliation Bill known as the “One Big Beautiful Bill” or H.R. 1. While this federal budget legislation has several impacts across our industry, tucked into H.R. 1 were two very important provisions that are expected to improve and provide more flexibility for HSA-eligible HDHPs. 

• Permanent Extension of the HDHP/Telehealth Exemption: H.R. 1 made permanent the now expired COVID-era exemption that allowed an HDHP to pay for Telehealth services before the HDHP’s deductible is met. This is impactful when you consider the following:
  • Pre-H.R. 1 – Without this now expired exemption, if an HDHP paid for Telehealth services before the deductible is met, the individual covered by the HDHP would be ineligible to contribute to their HSA for the year.
  • Post-H.R. 1 – This permanent change in the law now means that an individual covered by a qualifying HDHP will remain eligible to contribute to their HSA for the year if and when their HDHP pays for Telehealth services on a first-dollar basis.
• Direct Primary Care Services and HSAs: Prior to the enactment of H.R. 1, access to Direct Primary Care services was limited for individuals covered by an HDHP. This change in the law is also impactful because:
  • Pre-H.R. 1 – If an individual covered by an HDHP accessed Direct Primary Care services, that individual would be rendered ineligible to contribute to their HSA for the year.
  • Post-H.R.1 – Direct Primary Care services can now be accessed without adversely impacting an individual’s HSA eligibility, provided the monthly cost of the Direct Primary Care arrangement does not exceed $150 for singles and $300 for families (adjusted for inflation starting in 2027) and the Primary Care services do not include procedures that require the use of general anesthesia, prescription drugs (other than vaccines), and laboratory services not typically administered in an ambulatory primary care setting. Also, starting in 2026, the monthly fees for a Direct Primary Care arrangement can now be paid for with tax-free HSA dollars. 

Educating and Engaging Employees About HSA-Eligible HDHPs 

Making permanent the HDHP/Telehealth exemption – as well as increasing access to Direct Primary Care services without adversely impacting an HDHP-planholder’s HSA eligibility – could very well make HSA-eligible HDHPs more attractive to workers across generational lines. These changes in the law may also offer employers additional tools to “engage” Gen Zers, as well as Millennials, Gen Xers and Baby Boomers. 

For example, employers may offer their workers access to engagement tools like a Decision Support platform, which can help employees sync health and wealth needs and integrated Care Navigation (which are intended to help employees access high-quality, top-performing in-network care, while improving outcomes and lowering costs). Employers can also educate employees on the importance of accessing Direct, in-network Primary Care, which offers the potential to produce savings to both employees as well as the employer. 

Telehealth is also a meaningful service that enables employees to obtain the care they need, when and where they need it, in a cost-effective and convenient manner. Now that Telehealth services can be more flexibly paired with an HSA-eligible HDHP, employers can leverage this change in law and adjust their benefit plans and tools to help employees better engage with their benefits, with the potential for optimal health outcomes and cost savings. 

Looking to the Future 

As our global economy and diverse workforce continue to evolve year-over-year, Congress and the Federal Departments will continue to respond with new policymaking impacting the benefits ecosystem. Case-in-point: Keep a look out for policymaking in the area of price transparency, accessing health claims data, and even in the area of ERISA’s fiduciary obligations later this year. 

Benefitfocus will also be at the forefront of the continued evolution of the benefits ecosystem through crunching the data and providing insights on current trends in the benefits industry, which will inform employers and policymakers on the future of employee benefits. Case-in-point: Keep an eye out for next year’s State of Employee Benefits Report and any additional insights from Benefitfocus throughout 2025. 

The information provided does not, and is not intended to, constitute legal advice; instead, all information and content herein is provided for general informational purposes only and may not constitute the most up-to-date legal or other information. Benefitfocus does not act in a fiduciary capacity in providing products or services; any such fiduciary capacity is explicitly disclaimed. This summary is provided by a consultant to Benefitfocus.com, Inc., and any opinions expressed within do not necessarily reflect those of Benefitfocus.com, Inc. or its affiliates and are not intended to provide specific advice or recommendations for any plan or individual. 

The State of Employee Benefits 2025 was compiled from enrollment transactions aggregated across 316 large employers (1,000+ full time employees) within the Benefitfocus customer base, representing more than 1.8 million employees in total. The data was evaluated on an anonymous basis. Enrollment records include both active and passive enrollments made by a variety of industry roles (employee, carrier representative, broker, benefits administrator, etc) from the fall of 2022 through fall of 2024 for plan year effective dates of January 1. These measurements are not meant to be a nationally representative sample, but to represent the aggregate activity for large employers on the Benefitfocus platform.

Benefitfocus.com, Inc. and its affiliated companies (collectively, “Benefitfocus”) is making available to you the Personalized Decision Support tool offered by SAVVI Financial LLC (“SAVVI”). Benefitfocus is a Voya Financial(“Voya”) business. Voya has a financial ownership interest in SAVVI, including representation on SAVVI’s board of directors, and also maintains business relationships with SAVVI that create an incentive for Voya to promote SAVVI's products and services and for SAVVI to promote Voya's products and services. Please access and read SAVVI’s Firm Brochure, which is available at this link: https://www.savvifi.com/legal/form-adv. It contains general information about SAVVI’s business, including conflicts of interest. 

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