COVID-19 Employer Playbook

Free COVID-19 Testing

Mandate to Cover Testing Group health plans and insurers must cover FDA-approved diagnostic products to detect the virus that causes COVID-19. No Cost Share Benefits for COVID-19 testing must be provided without any cost-sharing. That means no deductibles, no copays, no coinsurance, and no other form of out-of- pocket expense to the employee. In addition, preauthorization and any other form of medical management are also prohibited. What is Included? No cost coverage requirements include costs for the actual test (nasal swab and lab analysis) plus any related services or provider services. This includes visits to urgent care, emergency room, in-person or telehealth provider that result in an order for or administration of a covered diagnostic test. Impacted Plans This requirement applies to all health plans. This includes self-funded plans and all fully insured plans (regardless of the state in which they are situated). In addition, ACA grandfathered plans are also subject to this Act. However, it appears that excepted benefit plans and retiree-only plans are not subject to this provision. Note that it is essentially unheard of for a federal mandate to sweep across all health plan types.

Are Insurance Plans Responding Quickly? Most insurance carriers are already well down the road of implementing free coverage for COVID-19 testing. Many implemented these provisions prior to the law requiring them. What about HDHP/HSA Plans? Authorities have confirmed that the free testing provisions, when added to an HDHP plan (prior to the deductible), will not disqualify the plan as an HDHP plan. This means that individuals may continue to make contributions to an HSA without concern. CARES Act Expansions The CARES Act (passed eight days after the FFCRA) expanded the types of testing that plans must cover without cost-sharing. The amended provisions now require plans to also cover, without cost-sharing, any other forms of tests that are found to be necessary by the HHS. This open protection is designed to ensure that any future COVID- 19 testing protocols or services remain under the no-cost sharing umbrella. Effective Date and Duration The effective date of the free COVID-19 testing mandate is April 1, 2020. It should be noted, however, that many carriers already started covering the testing on a no-cost basis prior to the mandate. The mandate expires December 31, 2020.


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