In response to the coronavirus disease known as COVID-19, the Internal Revenue Service (IRS) has issued Notice 2020-15, which permits health savings accounts (HSAs) paired with high-deductible health plans (HDHPs) to cover COVID-19 testing and treatment before participants satisfy their deductibles. Specifically:
- HSA/HDHPs can cover COVID-19 testing and treatment without a deductible or a deductible that is lower than the minimum self-only or family deductibles (in 2020, $1,400 for self-only and $2,800 for family).
- This guidance applies to “all medical care services and items purchased associated with testing for and treatment of COVID-19.”
- The IRS also notes that vaccinations continue to be considered “preventive” under the HSA rules. Therefore, if a COVID-19 vaccine becomes available, HSA/HDHPs will be able to provide pre-deductible coverage.
We recommend that employers offering HSAs paired with HDHPs:
- Work with their health plan or TPAs to determine how copays, deductibles, or other cost-sharing will apply to COVID-19 testing and treatment;
- Amend plan documents and other disclosures as needed; and
- Determine how plans will communicate any plan changes to participants.
- IRS Notice 2020-15: High Deductible Health Plans and Expenses Related to COVID-19
- COVID-19 or Other Public Health Emergencies and the Family and Medical Leave Act Questions and Answers
The Business Group hosted a webinar on Tuesday March 17, 2020 during which we discussed this and other regulatory developments for group health plans. Members can access the slides and recording at our Events page.