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IRS Issues Helpful Coronavirus-Related Guidance for Employers with High Deductible Health Plans

By Beth Alcalde on March 13, 2020
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Benefit plan sponsors are responding to participant questions about the coronavirus/COVID-19. In particular, employers’ HR departments are fielding questions about whether their health plan will pay for any necessary testing and/or treatment. Both full-insured and self-funded plans are widely announcing plans to waive the cost of physician-ordered tests. But until now, there was one huge open question. Could participants in certain consumer-driven health plans actually take advantage of those financial offerings without adverse tax implications? That issue is created because the IRS has rigid requirements on High Deductible Health Plans (HDHP) in order to allow participants to also contribute to a Health Savings Account (HSA). In general, if an HSA participant has not met the required deductible, any non-preventive services cannot be discounted or offered for free. Absent any guidance from the IRS, therefore, employers with multiple health plan options would have been able to offer free tests to some employees but not to others.

Fortunately for employers and employees alike, on Wednesday, March 11, 2020, the IRS issued Notice 2020-15, confirming that a health plan will not fail to satisfy the High Deductible Health Plan (HDHP) requirements, and a participant will not be disqualified from contributing to a Health Savings Account (HSA), simply because the health plan provides health benefits associated with testing for and treatment of COVID-19 without a deductible, or with a deductible below the minimum statutory deductible required for an HDHP.

Tags: Coronavirus
Photo of Beth Alcalde Beth Alcalde

A noted employee benefits lawyer, author, and speaker, Beth Alcalde represents Fortune 500 companies and other public and private entities, including those in the hospitality, healthcare, and higher education sectors, throughout the United States. As a leader within the firm, Beth is a…

A noted employee benefits lawyer, author, and speaker, Beth Alcalde represents Fortune 500 companies and other public and private entities, including those in the hospitality, healthcare, and higher education sectors, throughout the United States. As a leader within the firm, Beth is a longtime member of Akerman’s Board of Directors, and is also a current member of Akerman’s Executive Committee. Previously she chaired the firm’s Professional Development Committee, and served as office managing partner of the firm’s Palm Beach County offices. Noted in Chambers USA as “terrific at coming up with imaginative solutions,” Beth provides counsel on employer-sponsored benefit plans, from compliance with ERISA, the Affordable Care Act, and other federal regulations, to internal audits and benefits-related implications of corporate transactions. She assists clients in defending and responding to audits conducted by the Internal Revenue Service (IRS), U.S. Department of Labor (DOL), and U.S. Department of Health and Human Services (HHS). Of particular emphasis, Beth has represented group health plan sponsors in responding to audits of the quantitative and non-quantitative treatment limitations within their plans, as required by the Mental Health Parity and Addiction Equity Act.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    HR Defense
  • Organization:
    Akerman LLP
  • Article: View Original Source

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