In response to the end of the COVID-19 Public Health Emergency and National Emergency Period, the IRS recently published additional guidance regarding the coverage that High Deductible Health Plans (HDHPs) can provide while maintaining their Health Savings Account (HSA) qualified status. This update carries important implications for individuals and groups enrolled in HSA-qualified HDHPs.

During the COVID-19 emergency period, the IRS had allowed HDHPs to cover COVID-19 testing and treatment without subjecting it to the plan's deductible. The newly issued guidance clarifies that this relief will continue until the end of the plan year on or before December 31, 2024. This means that HDHPs with calendar year plans will need to apply the deductible to COVID-19 testing and treatment services once their plan is renewed in 2025. Non-calendar year HDHPs must begin applying the deductible from the plan renewal in 2024.

It's important to note that the updated guidance has no impact on COVID-19 vaccinations, which still qualify as preventive care. HDHPs will continue to cover COVID-19 vaccinations without applying the deductible, ensuring individuals have access to this crucial preventive measure.

Participants in HSA-qualified HDHPs can contribute to their HSA accounts if they are enrolled solely in an HSA-qualified HDHP and have no other disqualifying coverage. While the guidance modifies the coverage for COVID-19 testing and treatment, it reiterates that the eligibility criteria for HSA contributions remain unchanged.

Employers should review their plans to ensure they align with the updated requirements. It is always advisable to consult with your benefits administrators for specific guidance based on individual circumstances.

If you have questions or have questions, please don’t hesitate to contact us.

Sources: Larry Grudzien, Attorney At Law