EB Flash: COVID-19 Testing and Treatment Available Without a Deductible

Employee Benefits Alert
03.11.2020

The Internal Revenue Service (IRS) today issued Notice 2020-15, which preserves the status of a high deductible health plan (HDHP) under Internal Revenue Code section 223(c)(2)(A) if it "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." 

The IRS explains that a person covered by an HDHP "will not be disqualified from being an eligible individual under section 223(c)(1) who may make tax-favored contributions to a health savings account (HSA)." The guidance further provides that "all medical care services received and items purchased associated with testing for and treatment of COVID-19 that are provided by a health plan without a deductible, or with a deductible below the minimum annual deductible otherwise required under section 223(c)(2)(A) for an HDHP, will be disregarded for purposes of determining the status of the plan as an HDHP."

The three-page text of Notice 2020-15 is posted here.

An IRS press release on the guidance is posted here.


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