The Internal Revenue Service (“IRS”) released guidance on Wednesday, March 11, 2020, clarifying that testing and treatment of 2019 Novel Coronavirus (COVID-19) is preventive care and may be covered, pre-deductible, by a High Deductible Health Plan.
IRS Notice 2020-15 explains that this accommodation is due to the “unprecedented public health emergency posed by COVID-19.” This guidance follows an announcement from the White House on Tuesday, March 10, 2020, that major health insurers had agreed to cover testing and treatment of COVID-19 free of charge.
The IRS’s quick action helps to ensure that health savings account (HSA) participants will continue to be able to contribute to their HSAs through this time of heightened medical concern.
The following is an excerpt from the “Relief” section IRS Notice 2020-15:
“Due to the unprecedented public health emergency posed by COVID-19, and the need to eliminate potential administrative and financial barriers to testing for and treatment of COVID-19, a health plan that otherwise satisfies the requirements to be an HDHP under section 223(c)(2)(A) will not fail to be an HDHP merely because the health plan provides medical care services and items purchased related to testing for and treatment of COVID-19 prior to the satisfaction of the applicable minimum deductible. As a result, the individuals covered by such a plan will not fail to be eligible individuals under section 223(c)(1) merely because of the provision of those health benefits for testing and treatment of COVID-19.”