Carriers in multiple states took the proactive step to affirmatively state that they will cover diagnostic testing and treatment for COVID-19 without cost-sharing for their fully-insured books of business.  Self-insured plan sponsors were also contacted about whether they sought to cover diagnostic testing and treatment for COVID-19 without cost-sharing. Due to ambiguity in the regulations, one issue raised by the coverage change was whether providing coverage for COVID-19 testing and treatment without cost-sharing constitutes first-dollar coverage that would make an individual ineligible for HSA contributions.

In response to the questions surrounding this ambiguity, the IRS released Notice 2020-15, which states that individuals can make tax-favored contributions to an HSA, even if, “the health plan provides health benefits associated with testing for and treatment of COVID-19 without a deductible, or with a deductible below the minimum deductible (self only or family) for an HDHP.”  This guidance clarifies that a plan sponsor who provides COVID-19 testing and treatment to HDHP participants with no cost-sharing, or cost-sharing below the usual required HDHP deductible, will not negatively impact those participants’ eligibility for continued contributions to their HSAs.

Hays Companies Research and Compliance will continue to monitor this evolving situation for further updates.


Please be advised that any and all information, comments, analysis, and/or recommendations set forth above relative to the possible impact of COVID-19 on potential insurance coverage or other policy implications are intended solely for informational purposes and should not be relied upon as legal advice. As an insurance broker, we have no authority to make coverage decisions as that ability rests solely with the issuing carrier. Therefore, all claims should be submitted to the carrier for evaluation. The positions expressed herein are opinions only and are not to be construed as any form of guarantee or warranty. Finally, given the extremely dynamic and rapidly evolving COVID-19 situation, comments above do not take into account any applicable pending or future legislation introduced with the intent to override, alter or amend current policy language.


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