Our March 24, 2020, What You Need to Know Now examined the federal law requiring all group health plans to cover the full cost of COVID-19 testing free of charge and without any employee cost-sharing, including deductibles, copayments or coinsurance. In addition, the health plan cannot require prior authorization or impose other medical management requirements. This includes both the cost of a testing kit and administration of the test. Subsequently, the CARES Act expanded the kinds of testing required to be covered without any cost to individuals. Because the national public health emergency has been extended, group health plans must provide this testing without any cost-sharing by individuals through at least October 23, 2020. Presently, health plans must provide cost-free coverage for:
- In vitro diagnostic tests for the detection and diagnosis of COVID-19 that are FDA-approved; the developer of which has requested, or intends to request, emergency use authorization from the FDA; or developed in or authorized by a State that informs the Department of Health and Human Services (HHS) of its intention to review tests to diagnose COVID-19 (including serological/antibody tests); or other tests that HHS determines to be appropriate.
- The cost of administering the test
- The costs of visits to a health provider’s office(s), urgent care center or emergency room. To be covered free of charge, these visits must result in the ordering of testing, the administration of testing, or an evaluation to determine whether testing is needed. Office visits include “telemedicine” visits under a health plan.
However, the Act covers only testing and diagnostics, not treatment of COVID-19. You should check with your health plan or insurer to learn if cost-sharing, including deductibles and copayments, and pre-approval requirements apply to treatment of the virus. Some health plans have decided to waive cost-sharing for treatment and high-deductible plans may cover treatment of COVID-19 before an individual’s deductible is met. We will continue to monitor developments at the federal and state level affecting health care coverage during this health emergency. Follow LR on LinkedIn to stay up to date.