For an update on the Families First Coronavirus Response Act, which requires coverage of testing without cost sharing effective March 18, 2020, see our blog entry.

In an effort to remove barriers to testing for and treatment of the 2019 Novel Coronavirus (COVID-19), the Internal Revenue Service today issued Notice 2020-15. The Notice permits qualifying high deductible health plans (HDHPs) to provide testing and treatment for COVID-19 prior to the application of any deductible, or with a lower deductible than would otherwise apply under the plan, without jeopardizing the status of the HDHP under the Code. The IRS confirmed that individuals with HDHPs providing this coverage may continue making tax-favored contributions to their health savings accounts. The guidance will apply indefinitely, until future guidance is issued by the IRS. The Notice also included a reminder that vaccinations continue to be considered preventive care that can be paid for by a HDHP (and, as a result, may be covered prior to applying a deductible).

The IRS Notice follows similar moves by many major U.S. health insurers over the past week. Actions announced by insurers include waivers of cost-sharing and deductibles for testing, waivers of pre-approval requirements, expanded access to telemedicine and nurse hotlines, greater flexibility regarding medication refill limits, and increased mental health support.