Skip to Main Content

Agencies Release Guidance on Coverage of OTC COVID-19 Tests

Thursday, February 24, 2022
Natalie Terchek
Agencies Release Guidance on Coverage of OTC COVID-19 Tests
  • Dec. 1, 2021: President Biden announced that guidance would be issued clarifying coverage of OTC COVID-19 tests.
  • Jan. 10, 2022: Federal agencies issued the guidance implementing the requirements for coverage of OTC COVID-19 tests.
  • Jan. 15, 2022: Deadline for plans and issuers to provide coverage for OTC COVID-19 tests available without a health care provider order or assessment. 

On Jan. 10, 2022, the Departments of Health and Human Services (HHS), Labor and the Treasury issued guidance regarding the requirements for health insurance issuers and group health plans to cover over-the-counter (OTC) COVID-19 diagnostic tests.


Plans and issuers must cover the costs of COVID-19 tests during the COVID-19 public health emergency without imposing any cost-sharing requirements, prior authorization, or other medical management requirements.

Under guidance issued in June 2020, at-home COVID-19 tests had to be covered only if they were ordered by a health care provider who determined that the test was medically appropriate for the individual. At that time, the FDA had not yet authorized any at-home COVID-19 diagnostic tests. Since then, several types of OTC at-home tests have been approved.

As of Jan. 15, 2022, the cost of these tests must be covered, even if they are obtained without the involvement of a health care provider. However, the FAQs do not require tests to be covered if they are not for individualized diagnosis (such as tests for employment purposes). 


Plans and insurance issuers may place some limits on coverage, such as:

  • Requiring individuals to purchase a test and submit a claim for reimbursement, rather than providing direct coverage to sellers.
  • Providing direct coverage though pharmacy networks or direct-to-consumer shipping programs and limiting reimbursements to other sources (the actual cost of the test, or $12, whichever is lower).
  • Setting limits on the number or frequency of OTC COVID-19 tests that are covered (no less than 8 tests per month or 30-day period).
  • Taking steps to prevent, detect and address fraud and abuse.

Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your legal or medical needs.

Get Started

Let Your Aspirations Set the Agenda

Grow with who you know. Reach out to us today and start the conversation, so you’re better protected and prepared for what comes next.

Talk to an Advisor

man looking left