Guidance on High Deductible Health Plans During COVID-19

On March 11, 2020, the Internal Revenue Service (IRS) issued Notice 2020-15 to allow high deductible health plans (HDHPs) to pay for COVID-19 testing and treatment before plan deductibles have been met, without jeopardizing their status. The IRS also noted that any COVID-19 vaccination costs count as preventive care and can be paid for by an HDHP without cost-sharing.

Effective March 27, 2020, the Coronavirus Aid, Relief and Economic Security Act (CARES Act) allows HDHPs to provide benefits for telehealth or other remote care services before plan deductibles have been met, for plan years beginning before Jan. 1, 2022.

HDHP Coverage Requirements

Only individuals who are covered by HDHPs can make contributions to HSAs. To qualify as an HDHP, a health plan cannot pay medical expenses (other than preventive care) until the annual minimum deductible has been reached. IRS Notice 2020-15 and the CARES Act provide exceptions to this general rule to encourage testing for and treatment of COVID-19.

In addition, effective March 18, 2020, the Families First Coronavirus Response Act (FFCRA) requires group health plans and health insurance issuers to cover COVID-19 testing without imposing any cost-sharing (such as deductibles, copayments, or co-insurance) or prior authorization or other medical management requirements.

In Summary

  • Employer-sponsored group health plans must cover COVID-19 testing without imposing a deductible, co-payment, or other cost-sharing.
  • HDHPs can pay for COVID-19 testing and treatment before the deductible is met without jeopardizing their status as HSA-compatible.
  • HDHPs can also pay for telehealth service before applying a deductible.

Action Steps

Employers with HDHPs should consult with their plan’s issuer or benefits administrator regarding their plan’s benefits for COVID-19 testing and treatment.

For additional information, please contact the Curi Benefit Solutions team by calling 800-662-7917.

News & Knowledge
All Curi recommendations are based on current CDC criteria at the time of publication. CDC guidance for SARS-CoV-2 infection may, or may not, be adopted by state and local health departments to respond to rapidly changing local circumstances. Providers should always check with their local health department to see if the CDC’s guidance on any given topic has been modified (particularly if more restrictive) from the CDC’s recommended guidelines. Follow this link https://www.cdc.gov/publichealthgateway/healthdirectories/index.html for contact information to your state/local health department. If local recommendations vary from those of the CDC, and you are unsure what recommendations to follow, then it is safer to follow the more restrictive guidelines/recommendations.