Employers across the country are currently considering what actions to put in place in light of the potential spread of COVID-19 (the coronavirus). Many employers offer their employees high-deductible health plans that can only cover certain preventive care expenses for their employees until the employee satisfies the deductible set by the plan. The IRS has just announced a high deductible health plan will not lose its high deductible health plan status if it chooses to cover “all medical care services received and items purchased associated with testing for and treatment of” the coronavirus without regard to the plan’s deductible or other cost sharing provisions. This is consistent with some states who are requiring that health insurance carriers cover various coronavirus-related expenses.

For employers that sponsor self-insured medical plans, no employer is obligated to make this change to their group health plan, but IRS Notice 2020-15 opens the door for employers to relax deductibles and other out-of-pocket limits for coronavirus-related expenses. Employers who decide to provide this coverage may have to amend their plans to provide the benefit and issue a summary of material modifications, which amends their summary plan description. Employers who wish to make this change should work with their insurance providers and/or third-party administrators.