IRS OKs HDHP Coverage of Coronavirus Testing

High-deductible health plans (HDHPs) will not lose their special status merely because they cover the cost of testing for or treatment of COVID-19 before plan deductibles have been met.

The Internal Revenue Service (IRS) has advised that high-deductible health plans (HDHPs) can pay for 2019 novel coronavirus, or COVID-19, testing and treatment without jeopardizing their status as HDHPs.

According to the IRS, this also means that an individual with an HDHP that covers these costs may continue to contribute to a health savings account (HSA).

The IRS’s stance is detailed fully in Notice 2020-15, which was posted today on In the notice, the IRS also explains that, as in the past, any vaccination costs continue to count as preventive care and can be paid for by an HDHP.

“Today’s notice applies only to HSA-eligible HDHPs,” the IRS states. “Employees and other taxpayers in any other type of health plan with specific questions about their own plan and what it covers should contact their plan.”

The IRS says part of the federal government’s response to COVID-19 is removing barriers to testing for and treatment of COVID-19.

“Due to the nature of this public health emergency, and to avoid administrative delays or financial disincentives that might otherwise impede testing for and treatment of COVID-19 for participants in HDHPs, this notice provides that all medical care services received and items purchased associated with testing for and treatment of COVID-19 that are provided by a health plan without a deductible, or with a deductible below the minimum annual deductible otherwise required under section 223(c)(2)(A) for an HDHP, will be disregarded for purposes of determining the status of the plan as an HDHP,” the IRS states.

The IRS also clarifies that Notice 2020-15 “does not modify previous guidance with respect to the requirements to be an HDHP in any manner other than with respect to the relief for testing for and treatment of COVID-19.”

“This notice provides flexibility to HDHPs to provide health benefits for testing and treatment of COVID-19 without application of a deductible or cost sharing,” the IRS states. “Individuals participating in HDHPs or any other type of health plan should consult their particular health plan regarding the health benefits for testing and treatment of COVID-19 provided by the plan, including the potential application of any deductible or cost sharing.”