It’s a gray area, but it’s not that unclear.
A telehealth benefit that allows members to contact a physician by phone for no consult fee or a consult fee that equates to a copayment would likely disqualify the member from HSA eligibility if the doctor can provide a diagnosis and prescribe medications.
If the member pays the full cost of the consult, then it does not disqualify the member from HSA eligibility.
Not everyone has this same interpretation, and the IRS has never issued guidance on this.