Skip to Main Content

Information Related to Health Plan Coverage for Coronavirus (COVID-19) Testing

Tuesday, March 17, 2020

The expanding coronavirus is creating many challenges for employers and subsequent health insurance coverage questions.

As the COVID-19 outbreak continues to spread, employers may get questions from employees about their health plan’s coverage for COVID-19 testing, including whether they will need to pay a deductible or copayment. This is a rapidly evolving issue, with many health insurance issuers announcing that they will voluntarily waive any cost-sharing for COVID-19 testing. 

Key Points

  • A new federal law may be passed that will require group health plans and issuers to cover COVID-19 testing without cost-sharing. 
  • Some states already require issuers to cover COVID-19 testing without imposing deductibles or other cost-sharing. 
  • The IRS has clarified that HDHPs may provide first dollar coverage for COVID-19 testing without jeopardizing their status as HSA-compatible. 

A new federal law may be passed in the future requiring health plans and health insurance issuers to cover COVID-19 testing without cost sharing. (This requirement is included in the coronavirus relief bill that was passed by the House of Representatives on March 14, 2020.) In the meantime, employers should consult with their plan’s issuer or benefits administrator regarding their health plan’s coverage for COVID-19 testing. 

Federal Guidance

The federal government has released the following guidance on health plan coverage for COVID-19 testing: 

  • Insured health plans in the individual and small group markets must cover COVID-19 diagnosis and treatment as an essential health benefit, although the exact coverage details and cost-sharing amounts may vary by plan. 
  • High deductible health plans (HDHPs) that are compatible with HSAs can pay for COVID-19 testing  and treatment before an individual has met the plan’s minimum deductible for the year. 

State Requirements 

Many state insurance commissioners are requiring or encouraging health insurance issuers to waive cost sharing for COVID-19 testing. For example, California, New York, Washington and Massachusetts have directed issuers to cover COVID-19 testing without imposing any deductibles, copayments or other cost sharing. 

This Legal Update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. ©2020 Zywave, Inc. All rights reserved.


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