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HDHPs and COVID-19 treatments/screenings

As a reminder, in order for an individual to establish and contribute to an HSA, they must be enrolled in a qualified HDHP and cannot have any other first-dollar coverage (besides specific treatments defined as preventive care). 

IRS Notice 2020-15 provides that a plan will not fail to be a qualified HDHP only because the health plan provides medical care services and items purchased related to testing for and treatment of COVID-19 prior to meeting the minimum statutory deductible. In other words, the IRS guidance says that a plan that covers medical services related to screenings and treatments of COVID-19 at 100% with no employee cost-sharing will not disqualify someone from HSA-eligibility.

This specific notice does NOT say that the HDHP must cover medical treatments/screenings related to COVID-19. Instead, it says IF the HDHP does cover these particular benefits at 100% before the deductible is met (whether by state or federal mandate, or if the fully-insured carrier or self-insured plan agrees to waive any deductible expenses), this wouldn’t cause the plan to cease to be a qualified HDHP and therefore cause an individual to lose HSA-eligibility. 

For example, if a self-insured plan has announced it will cover any screenings and treatments related to COVID-19 with no cost-sharing on the employee’s part, that would not make her/him ineligible to continue contributing to the HSA.

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