On March 10, 2020, the American Benefits Council (ABC) asked the Internal Revenue Service (IRS) to clarify whether waiving cost-sharing for coronavirus testing and treatment before an enrollee’s deductible is met would disqualify enrollees or their employers from contributing to Health Savings Accounts (HSAs). Employers requested this clarity from the IRS because they feared they might violate IRS Notice 2004-23, which list a limited number of preventive services that a high deductible health plan (HDHP) can cover before an enrollee’s deductible is met for the plan to be eligible to be linked to an HSA.
On March 11, 2020, less than 24 hours after ABC’s request was submitted, the IRS published Notice 2020-15. This notice stated that health plans that otherwise satisfy the qualifications to be an HDHP will not fail to be an HDHP because the health plan provides coverage for testing for and treating coronavirus prior to an enrollee satisfying the plan’s minimum deductible or with a deductible that is below the minimum allowed annual deductible. Notice 2020-15 also reiterated that vaccinations qualify as preventive care, which allows HDHPs to waive cost-sharing requirements for a coronavirus vaccine when it becomes available. The IRS rationalized this policy change by calling attention to the “unprecedented public health emergency” that coronavirus presents and the need for eliminating barriers for testing and treatment of the virus. Following the publication of IRS Notice 2020-15, employer groups praised the IRS for finalizing the policy change so quickly.
Last Updated on May 18, 2020 by Aimed Alliance
