Seven Ways the Big, Beautiful Bill Could Impact Consumer Accounts
Big Changes May Be Coming. Elevate Is Ready.
On May 22, the U.S. House passed The One, Big, Beautiful Bill—a sweeping budget reconciliation package that includes tax and spending cuts that impact everything from the debt ceiling to Medicare eligibility. Within the bill are several provisions that could reshape consumer directed benefits, including HSAs, FSAs, and HRAs.
If the bill becomes law, many of these changes would go into effect for plan years starting in January 2026. But adapting to the new rules requires more than awareness—it demands infrastructure that is ready to respond.
The good news: Elevate’s infrastructure is already designed to handle regulatory updates quickly with no code rewrites, engineering backlogs, or downtime. Every rule, contribution limit, and eligibility filter can be adjusted through real-time configuration adjustments.
Here are seven ways consumer accounts might change, and how we’re prepared.
Top Consumer Account Provisions & How Elevate is Ready
- Expanded Eligibility for HSAs
What’s changing: More people become HSA-eligible, including Medicare Part A-only enrollees, people whose spouses have FSAs, and users of on-site clinics or direct primary care arrangements, all of whom are currently excluded. Additionally, bronze and catastrophic exchange plans will be considered qualified high-deductible plans for HSA eligibility.
→ Elevate’s approach: Our platform’s eligibility logic is fully configurable. No dev queue required—just update settings and go.
- CHOICE Arrangements Replace ICHRAs
What’s changing: These plans would be renamed (we can all agree this is an improvement!), and employee premiums under these plans may be paid pre-tax.
→ Elevate’s approach: Our HRA plan template builder already supports CHOICE-style plan designs. Our administrative partners can launch new plans for employer clients in minutes. Even plan names are flexible.
- Increased Contribution Limits
What’s changing: HSA limits would rise by $4,300 (individual) and $8,550 (family), with phase-out rules based on income levels.
→ Elevate’s approach: Contribution limits can be updated globally and instantly, including support for custom income phase-outs.
- HSA Catch-Up Contributions for Spouses
What’s changing: Spouses could split the HSA catch-up contribution however they want.
→ Elevate’s approach: We allow this allocation via plan setup or employee elections and can adjust spouse tracking without major programming delays. - Eligibility for Pre-Account Medical Expenses
What’s changing: Medical expenses incurred before the HSA is established may be reimbursed.
→ Elevate’s approach: Our system already tracks date of service. No change needed, just enable the setting.
- HRA/FSA-to-HSA Transfers
What’s changing: FSA or HRA can be terminated and rolled into HSAs under very specific rules.
→ Elevate’s approach: Our system can support the eligibility rules, manage terminated plans, apply contribution caps, and comply with any W-2 reporting requirements.
- New Qualified Expenses: Fitness & Exercise
What’s changing: HSAs could cover gym memberships and exercise instruction, capped annually at $500 for individuals and $1,000 for family coverage.
→ Elevate’s approach: New expense types can be added to our system without engineering lift. Additionally, we can support tracking of this expense type or leave it up to consumer attestation (per plan sponsor rules).
More Complex Scenarios. Check.
Embedded within some of these provisions are more complex settings. On the surface level, these changes may seem simpler than they actually are, but there are very complicated implications layered underneath. As other platform providers struggle to build the basics, these details could be overlooked on less flexible systems.
Let’s dive into a few of them.
- Catch-Up Contributions for Spouses: Dependent Spouse Turns 55+ in Tax Year
Elevate’s system dynamically adjusts contribution maxes when either account holder qualifies for a catch-up. This current functionality can be expanded to include dependent spouses under family coverage.
- HRA/FSA-to-HSA Terminations and Transfers
This one’s tricky—but we’ve got it. Our system has built-in flexibility to meet complex requirements.- Eligibility check: Enforce eligibility requirements before rollovers are allowed.
- Plan conversion: Auto-convert terminated plans to meet guidelines.
- Contribution limits: System adjustments to validate rollover limits against complex IRS caps.
- Tax reporting: Elevate already supports W-2 integration. These rolled funds can be reported accurately and automatically.
What This Means for Partners, Employers, and Account Holders
If these provisions become law, most platforms will have to scramble to catch up. As legacy platform providers divert resources to building out quick-fix patches on top of aging tech solutions, attention to new features will take a back seat.
Whatever the bill ultimately entails, Elevate won’t need to divert resources to meet them. We built this infrastructure to handle evolving rules without introducing delays or risk. Working with Elevate means:
- Immediate updates to contribution limits and eligibility rules
- Real-time configuration of new plan types and expenses
- Automated compliance checks and tax reporting
The Bottom Line
When laws change, you don’t want to be stuck waiting or for your system to suffer during buildouts. Elevate moves instantly. So you stay compliant, competitive, and ahead of the curve.
For more details, see The One, Big, Beautiful Bill and a more detailed explanation of these provisions, prepared by the staff of the Joint Committee on Taxation for the mark up of the bill by the House Ways and Means Committee and provided by the Employers Council on Flexible Compensation.
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