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-19 (coronavirus) pandemic, those rules have been 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. 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.
Coverage of COVID testing and vaccines with no cost-sharing
For the duration of the COVID-19 public health emergency (currently extended though at least mid-October 2022), the federal government and numerous states are requiring health plans to cover COVID testing with no cost-sharing, which means the insured doesn’t have to pay anything for the service. COVID vaccines also have to be covered at no cost to the enrollee. And as of 2022, health plans are required to cover the cost of up to eight at-home COVID tests per member, with no cost-sharing.
These rules apply to HDHPs just like any other plan, so the IRS announcement was important in terms of clarifying that people with HDHPs would still be able to contribute to HSAs, despite the fact that their health plans are now required to pay for some additional services (that aren’t on the federally defined list of preventive services) pre-deductible.
Cost-sharing for treatment of COVID-19
Although the IRS has allowed HDHPs to cover COVID treatment without a deductible, the federal government is not requiring health plans to cover COVID treatment without cost-sharing, and neither are most states (keeping in mind that treatment is not the same thing as testing and vaccinations, both of which do have to be covered without cost-sharing).
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 dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.