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IRS: HDHP-HSA Plans May Cover COVID-19 Costs as Preventive Care

Legislative Alert

1.5 minute read

The Internal Revenue Service has advised that HDHPs (High-Deductible Health Plans) can pay for 2019 Novel Coronavirus (COVID-19)-related testing and treatment, without jeopardizing their status (IRS Notice 2020-15). This also means that an individual with an HDHP that covers these costs may continue to contribute to a health savings account (HSA).

In Notice 2020-15, the IRS said that health plans that otherwise qualify as HDHPs will not lose that status merely because they cover the cost of testing for, or treatment of, COVID-19 before plan deductibles have been met. The IRS also noted that, as in the past, any vaccination costs continue to count as preventive care and can be paid for by an HDHP.

Today's notice applies only to HSA-eligible HDHPs. Employees and other taxpayers in any other type of health plan with specific questions about their own plan and what it covers should contact their insurance carrier or NIS Consultant.

Coverage Issues

There have been many updates in this area. States like California have already issued a notice telling all fully-insured carriers to cover the costs without any cost-sharing measures. Self-funded plans have options about covering the costs with or without cost-sharing measures. Some TPAs are taking the position that they are covered without cost-sharing unless/until a self-funded group opts out.

Please check with your NIS Consultant about how this may affect your plan. And, rest assured that with IRS Notice 2020-15, if you choose to have the cost covered without deductible, copay or coinsurance, your plan participants' HSAs will not be affected.

Prior Guidance/Links: 


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This blog is intended to be a compilation of information and resources pulled from federal, state and local agencies. This is not intended to be legal advice. For up to the minute information and guidance on COVID-19, please follow the guidelines of the Centers for Disease Control and Prevention (CDC) and your local health organizations.

National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.

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Aaron Casper

Aaron Casper

Aaron A. Casper, Employee Benefits Consultant at NIS (National Insurance Services), understands the unique way governmental organizations operate, manage risk and develop budgets; hence, he delivers reliable solutions for his clients without short cuts or temporary fixes. Aaron advocates for his clients and prides himself on building authentic relationships, even passing up potential short-term opportunities if it doesn’t make long-term sense for his clients. His straightforward nature, integrity and astute sense of humor are why his customers consider him a valued strategic resource. Aaron Casper is a licensed insurance agent. He specializes in health insurance consulting for Minnesota schools, cities and counties including fully insured, self-insured, and stop-loss plans. Additionally, he has experience implementing OPEB liability reduction strategies as well as ensuring his clients are ACA compliant.