On March 11, 2020, the IRS issued Notice 2020-15, allowing health savings account (HSA)-compatible high deductible health plans (HDHPs) to provide coverage for testing and treatment of COVID-19-related services without an annual deductible requirement or with a lower annual deductible than that otherwise required under the HDHP IRS regulations.

The IRS provided this relief, “due to the nature of this public health emergency, and to avoid administrative delays or financial disincentives that might otherwise impede testing for and treatment of COVID-19 for participants in HDHPs…”

The Notice does not require HDHPs to provide COVID-19-related coverage without the deductible requirement, but provides HDHPs the flexibility to do so without risk of disqualification for HSA contributions. The Notice does not change any prior guidance or regulation issued with respect to the HDHP requirements. 

HDHP plan documents do not need to be amended at this time, but employers that would like to provide coverage for COVID-19-related services under their self-funded plans without the HDHP deductible requirement should inform their claims administrators and provide notice of the changes to the HDHP participants.