In reaction to growing concerns about testing for and treatment of COVID-19, clients with high-deductible group health plans (and related health savings accounts) have been asking whether plans can provide testing and treatment of COVID-19 at no cost to participants. This morning, the IRS released Notice 2020-15, which provides that a group health plan can still be considered a high-deductible health plan (HDHP) if it provides health benefits for the testing and treatment of COVID-19 without requiring that participants first meet the minimum plan’s deductible. This guidance will give employers and plans the flexibility to pay for testing and treatment for all plan participants, regardless of whether participants are relying on a plan’s HDHP status to make contributions to a health savings account.

Prior to this notice, employers were unclear about whether paying for testing and treatment of COVID-19 would prevent participants from contributing to health savings accounts. This notice gives employers one less thing to worry about when preparing their responses to questions related to COVID-19.