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Over-the-Counter COVID-19 Test Guidance

Over-the-Counter COVID-19 Test Guidance

1.5 minute read

The Departments of Labor, Health and Human Services, and the Treasury issued FAQ guidance regarding the requirements to cover over-the-counter (OTC) COVID-19 diagnostic tests for group health plans and insurers.

As of January 15, 2022, plans and insurers must cover the cost for OTC COVID-19 tests even if they are obtained without the involvement of a health care provider. However, the FAQs do not require tests to be covered if they are not for individualized diagnosis (such as tests for employment purposes).

Plans and insurance issuers may place some limits on coverage, such as:

  • Taking steps to prevent, detect, and address fraud and abuse.
  • Requiring individuals to purchase a test and submit a claim for reimbursement, rather than providing direct coverage to sellers.
  • Providing direct coverage through pharmacy networks or direct-to-consumer shipping programs and limiting reimbursement to other sources (the actual cost of the test, or $12, whichever is lower)
  • Setting limits on the number or frequency of OTC COVID-19 tests that are covered (no less than 8 tests per month or 30-day period).

Download the bulletin for more details.


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.

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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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Rick Labian

Rick Labian

Rick Labian lives by the Golden Rule – he is guided by what is best for his clients and treats others as he would like to be treated. Rick acts as an advisor and advocate for his clients, helping to identify goals for their benefit programs and building a strategic plan together. Rick has a rich history with NIS. He has worked for NIS for over 20 years, leading the Eastern region. Rick is the manager and leads the FBC Client Management Team. Rick’s leadership and experience aids our internal staff and all of NIS’ FBC clients. Rick is a licensed insurance agent and is ACA certified through the National Association of Health Underwriters.