Benefits document surrounded by orange pill bottles and stethoscope.

High-deductible health plans may now cover testing and treatment for 2019 novel coronavirus (COVID-19) on a first-dollar basis without risking making participants ineligible to participate in health savings accounts (HSAs). The Internal Revenue Service (IRS) released a notice providing temporary relief for high-deductible health plans covering COVID-19-related health care services and supplies before the minimum deductible is met.

The IRS is granting cost-sharing relief for COVID-19 testing and treatment to remove administrative delays and financial disincentives that may otherwise discourage individuals from getting tested and treated for the illness. The IRS reserves the right to terminate such relief by future notice.

The IRS notice will be especially welcome in states such as California, New York, and Washington, which have required insurers (though not self-insured plans) to waive all health plan cost-sharing associated with COVID-19 testing.

Other proposals are also circulating to increase access to COVID-19 coverage. Legislation has been proposed in the House of Representatives to add COVID-19 testing to the Affordable Care Act (ACA)’s list of preventive health services that health plans are required to cover on a first-dollar basis. Vice President Mike Pence also recently announced the administration’s plans to deem COVID-19 tests an ACA “essential health benefit,” meaning individual policies would have to cover the testing and group health plans would have to meet the ACA cost-sharing rules with respect to testing.

Ogletree Deakins’ coronavirus team has covered various aspects of the 2019-nCoV outbreak and provided an overview of recent developments, tips from a workplace safety perspective, and information affecting international employers. The team will continue to monitor the evolving situation and report on the issues on our Coronavirus (COVID-19) Resource Center for Employers.



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