By Julie R. Shank, Esq.

In an effort to remove administrative barriers that may curtail the response to COVID-19, the Internal Revenue Service recently issued guidance in Notice 2020-15, stating that a high deductible health plan (HDHP) will not violate the Internal Revenue Code if it provides health benefits associated with testing for and treatment of COVID-19 without a deductible, or with a deductible below the minimum deductible for an HDHP. An individual with an HDHP covering these costs may continue to contribute to a health savings account (HSA). Employers wishing to provide coverage under this guidance without the deductible requirement should inform their participants and claims administrators.

It is also becoming easier for insureds to obtain greater supplies of their prescription medications in light of the COVID-19 pandemic. On March 6, America's Health Insurance Plans (AHIP) said it was "activating emergency plans to ensure that Americans have access to the prevention, testing, and treatment needed to handle the current situation." For example, many insurance companies are allowing people to get 90-day supplies of prescription medications instead of the standard 30-day supply. Since each insurer's policies vary at this point, employers can advise insureds to call their insurer to see if it has waived early refill and supply limits.

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If you are looking for guidance on how to prepare for COVID-19 or have questions about the issues mentioned in this alert, we can help. Please contact one of the following members of our Benefits team: