IRS Provides Guidance on HSAs and Associated HDHPs, and Coverage of COVID-19 Testing

The IRS has issued Notice 2020-15, addressing requests made to the agency for health savings account (HSA)-related guidance as the nation responds to the challenges of the COVID-19 (coronavirus) outbreak in the U.S. and worldwide.

The IRS was asked for confirmation that a high deductible health plan (HDHP) associated with an HSA could cover the cost of COVID-19 patient testing with no deductible—or a lower deductible—first being paid, and still remain an HSA-eligible health plan. An HDHP must generally meet certain plan deductible requirements in order for an individual to make HSA contributions. There are certain exceptions that allow health plan coverage without satisfying the plan deductible. One of these is for preventive care costs. There has been uncertainty as to whether COVID-19 testing would be considered preventive care.

In Notice 2020-15, the IRS states, “Until further guidance is issued, a health plan that otherwise satisfies the requirements to be a high deductible health plan (HDHP) under section 223(c)(2)(A) of the Internal Revenue Code (Code) will not fail to be an HDHP under section 223(c)(2)(A) merely because the health plan provides health benefits associated with testing for and treatment of COVID-19 without a deductible, or with a deductible below the minimum deductible (self only or family) for an HDHP. Therefore, an individual covered by the 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).”