Can I use my HSA to pay for COVID-19 testing and treatment?

IRS relaxed HDHP rules to address COVID testing and treatment

With the exception of preventive care, high-deductible health plans normally cannot pay for any medical services until the insured has met at least the minimum deductible set by the IRS. But in the face of the COVID pandemic, those rules were relaxed.

In March 2020, the IRS announced that HSA-qualified health plans would be allowed to pay for COVID-19 testing and treatment before the enrollee had met their deductible, without the health plan losing its HSA-qualified status.⁴ That guidance was expanded later in 2020 to clarify that a full testing panel, including flu, norovirus, and RSV, could be covered without the plan using its HDHP status.⁵

But the IRS issued updated guidance in 2023 to clarify that this flexibility would only continue through the end of 2024.⁶ Starting in 2025, a plan that pays for COVID testing or treatment before the minimum HDHP deductible is met would fail to be an HDHP.⁷

However, the One Big Beautiful Bill Act (OBBBA), enacted in 2025, expands the definition of HDHP to include all Bronze and Catastrophic plans purchased in the health insurance Marketplace, starting in 2026. These plans will not be required to conform to standard HDHP rules (such as not paying for non-preventive care pre-deductible), but people enrolled in them will still be eligible to contribute to an HSA.

So although IRS rules for HDHPs prohibit a plan from being an HDHP if it pays for COVID testing or treatment pre-deductible, that rule will not apply to Marketplace Bronze or Catastrophic plans, starting in 2026.

Coverage of COVID testing and vaccines

For the duration of the COVID public health emergency, which ended May 11, 2023, the federal government and numerous states required health plans — including HDHPs — to cover COVID testing with no cost-sharing, which meant the insured didn’t have to pay anything for the service (this included up to eight at-home COVID tests per member per month).

But that ended with the end of the public health emergency: Health plans no longer have to cover at-home COVID tests, and can require their regular cost-sharing for tests that people get at a medical office.

COVID vaccines still have to be covered at no cost to the enrollee — that did not change with the end of the public health emergency, and it applies to all non-grandfathered health plans, including HDHPs. But as noted above, there is some uncertainty about the future of COVID vaccine coverage under the second Trump administration.⁸

Cost-sharing for treatment of COVID-19

Although the IRS allowed HDHPs to cover COVID treatment without a deductible, the federal government never required health plans to cover COVID treatment without cost-sharing, and neither did most states.

(Keep in mind that treatment is not the same thing as testing and vaccinations; testing had to be covered without cost-sharing during the pubic health emergency, and vaccines still have to be covered without cost-sharing, albeit with the above-mentioned uncertainty about the future of this coverage requirement.)

Some health plans – including some HDHPs – opted to waive cost-sharing for COVID treatment in 2020, but this had mostly ended by 2021, once COVID vaccinations became widely available. If you get COVID and need treatment, you should generally expect to have to meet your plan’s regular cost-sharing obligations.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written hundreds of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.