IRS Issues Guidance on HDHP Coverage and COVID-19 Preventative Care

On May 11, 2023, the Secretary of Health and Human Services declared the COVID-19 National Health Emergency to be over. 

In response to that ruling, the IRS released Notice 2023-37. This notice removes COVID-19 testing and treatment from the list of “Preventive Care” options, meaning that those with High Deductible Health Plans (HDHPs) will need to meet their deductible before COVID-19 testing and treatment are covered by insurance or subject to a copayment. 

At this time, it is believed that the COVID-19 vaccines administered by an in-network provider will continue to be covered in full under most types of private insurance. There is the possibility that might change in the future, but for now, coverage will remain the same. COVID-19 vaccinations are, and will continue to be, covered under Medicare Part B. 

This notice will go into effect for plans ending on or before December 31, 2024. After that date, those with HDHP medical plans will need to meet their deductibles before COVID-19 preventative care, testing, and treatment will be covered by insurance.

We encourage employers to review the notice and to please reach out to us with questions.