Group Health Plan Coverage Implications: HDHP’S Can Cover COVID-19 Testing and Treatment Pre-Deductible

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On March 11, 2020, the IRS announced that high-deductible health plans (HDHPs) may cover COVID-19 testing and treatment without a deductible or with a deductible below the required minimum deductible for HDHPs without losing their HDHP status under the Code or threatening the tax-favored treatment of participants’ health savings accounts (HSAs).

The notice applies broadly to “all medical care services received and items purchased associated with testing for and treatment of COVID-19.”  The full notice is available here.

This means the expenses related to the testing and treatment of novel coronavirus can be paid for by health plans with no member cost share. The health insurance carriers have responded and issued guidelines for covering testing (for all plan designs) as a preventive benefit (no cost-sharing).  ASO employers have been given the option of waiving member cost-share.  For the specific communication from the health insurance carriers:


Effective Immediately – Highmark will cover coronavirus, or COVID-19, testing when recommended by a medical professional based on your plan

Highmark recognizes how important it is to help those affected by COVID-19; that is why we are putting temporary program changes for our ASO customers into place, effective immediately. Under this temporary program, cost-sharing associated with physician-ordered diagnostic testing for novel coronavirus will be waived (this means copayments, deductibles, and coinsurance do not apply for this testing ) for all ASO members.


UPMC Health Plan Removes Barriers to Coronavirus Testing

UPMC Health Plan waives applicable deductibles, copayments, or other cost-sharing for COVID-19 testing when ordered by a member’s treating medical provider
As one of the largest integrated delivery systems in the nation, UPMC and UPMC Health Plan are committed to taking a leadership role in preventing the spread of the COVID-19 virus and caring for those who may be affected by it.

As part of this commitment, we are actively working to identify and remove any barriers that could unnecessarily delay or prevent our patients and members from receiving appropriate diagnosis and treatment in this challenging time. In order to ensure that no UPMC Health Plan member faces a financial barrier to receiving needed testing, we will waive any applicable deductibles, copayments, or other cost-sharing for COVID-19 testing when ordered by a member’s treating medical provider.

Effective immediately, this no-cost coverage of COVID-19 testing as a preventive service will apply for members in all of our commercial UPMC Advantage group and individual products, UPMC for Life Medicare Advantage plans, and our UPMC for You Medical Assistance plans; our self-insured or administrative services only (ASO) employer groups will be permitted to opt-out of preventive coverage at their discretion.

Commercial testing is expected to start becoming available over the weekend. We encourage any member with symptoms or suspected exposure to COVID-19 to immediately contact their health care provider or request a live, remote telehealth consultation available through our 24/7 UPMC AnywhereCare app.

For questions about locating a provider or available testing laboratory, our award-winning member services team is available Monday through Friday from 7 a.m. to 7 p.m. Saturday from 8 a.m. to 3 p.m. and can be reached at 1-844-220-4785 (TTY: 711). For additional information about COVID-19, please go to our website at

United Healthcare

Like you, we are concerned about the impact that COVID-19 could have on the health and wellbeing of the people we serve.

UnitedHealthcare has a team of experts closely monitoring COVID-19 and, as with any public health issue, we are working with and following all guidance and protocols issued by the U.S. Centers for Disease Control and Prevention (CDC), Centers for Medicare & Medicaid Services (CMS), Food and Drug Administration (FDA), state and local public health departments in supporting our members’ needs.
To help ensure our members have access to care, on March 7th UnitedHealthcare announced that we will waive member cost sharing for approved and authorized COVID-19 testing for fully-insured commercial, Medicaid and Medicare members.

Similar to our fully-insured approach, a number of our self-funded customers have asked about providing coverage of the COVID-19 tests without imposing cost share on their members. To support you and your employees during this challenging time, we intend to process covered COVID-19 testing claims without applying member cost sharing. This means the member cost share will be paid under your plan. COVID-19 testing claims will be processed with no member cost share for both fully-insured and self-funded plans effective April 1st, 2020.

As a self-insured customer, you have the right to opt out of this change; however, we strongly encourage you to support it. If you decide to opt out of this change, please contact your account representative by March 20, 2020.

Finally, eligible UnitedHealthcare and OptumRx members needing help obtaining an early prescription refill can call the customer care number located on the back of their medical ID card for assistance or work with their pharmacist who can assist in obtaining an override. We also encourage health plan members to use UnitedHealthcare’s Virtual Visit capability, available through the UnitedHealthcare app, to help answer any general questions or concerns.

Thank you for your patience and support during this challenging time. We expect the situation will evolve rapidly and we will continue to keep you updated as we have additional guidance and guidelines over the coming weeks and months.


We share the same goal: to help people get and stay healthy. We are your partners in health care,
and act to serve you, your employees and the millions of members who rely on us for their health
care needs.

As the COVID-19 situation continues to evolve, underscored by yesterday’s pandemic declaration
from the World Health Organization (WHO), we recognize the important role we play in addressing
this public health issue. Over the past few weeks, you’ve seen us take important steps to support the
health and well-being of our members and remove barriers to care.

We’ve put in place a comprehensive business continuity plan to minimize any potential business impact and ensure we continue to offer the services and operations you have come to expect. We’ve
also adjusted our internal policies to maintain a safe and healthy work environment for our CVS
Health colleagues. For your employees and members, we recently announced these resources and
enhancements when applicable:

• We’ve waived member out-of-pockets costs or cost sharing for COVID-19 diagnostic
testing and introduced zero co-pay telemedicine visits for the next 90 days, helping to
remove barriers to care.
• We’ve waived charges for home delivery of all prescription medications from CVS
Pharmacy. We’re also actively encouraging 90-day refills of eligible prescriptions and waiving
early refill limits on 30-day prescriptions for maintenance medications to prevent the
interruption of medication availability.
• We’ve introduced Healing Better care packages for members diagnosed with COVID-19,
supporting our members and helping to keep others in the home protected from potential
• We’re offering resources to help address any associated anxiety and stress related to
COVID-19, including opening Crisis Response Lines and expanding access 24×7 to the Aetna
Nurse Medical Line, among others.

Effective immediately, Aetna members will have access to the following resources:
Aetna will waive co-pays for all diagnostic testing related to COVID-19. This policy will cover the test kit for patients who meet CDC guidelines for testing, which can be done in any approved laboratory location. Aetna will waive the member costs associated with diagnostic testing at any authorized location for all Commercial, Medicare and Medicaid lines of business. Self-insured plan sponsors will be able to opt-out of this program at their discretion, please notify me by 1 pm on Monday March 9th if you would like to opt out.

For the next 90 days, Aetna will offer zero co-pay telemedicine visits for any reason. Aetna members should use telemedicine as their first line of defense in order to limit potential exposure in physician offices. Cost sharing will be waived for all video visits through the CVS MinuteClinic app, Aetna-covered Teladoc offerings and in-network providers delivering synchronous virtual care (live video-conferencing) for all Commercial plan designs. Self-insured plan sponsors will be able to opt-out of this program at their discretion, please notify me by 1 pm on Monday March 9th if you would like to opt out.

Through Aetna’s Healing Better program, members who are diagnosed with COVID-19 will receive a care
package containing CVS over-the-counter medications to help relieve symptoms. The package will also include personal and household cleaning supplies to help keep others in the home protected from potential exposure. Through existing care management programs, Aetna will proactively reach out to members most at-risk for COVID-19. Care managers will walk members through what they can do to protect themselves, where to get information on the virus, and where to go to get tested.


Cigna (NYSE: CI) customers will have access to coronavirus (COVID-19) testing, as prescribed by health practitioners, and the company will waive all co-pays or cost-shares to help fight the rapid spread of the virus in the U.S. and for its globally mobile customers.
“During this time of heightened concern, Cigna’s role is clear. We will do everything we can to help contain this virus, remove barriers to testing and treatment, especially for seniors and people who are chronically ill, and give peace of mind to those we serve,” said David M. Cordani, president and chief executive officer, Cigna. “This is another example of how, every day, we strive to stand by our customers through their life and health journeys.”
Current testing is available through the Centers for Disease Control and Prevention (CDC) and is being offered at no cost. Testing is expected to expand shortly as more commercial testing becomes available at a designated lab approved by the United States Food & Drug Administration. Cigna has committed to covering the medical test similar to a preventive benefit for fully-insured plans, thereby waiving co-pays, coinsurance or deductibles for customers. This includes customers enrolled in Cigna’s employer-sponsored plans in the United States, Medicare Advantage, Medicaid and the Individual & Family plans available through the Affordable Care Act. Organizations that offer Administrative Services Only (ASO) plans will also have the option to include coronavirus testing as a preventive benefit.
Procedure codes for health care providers are expected to be available April 1, 2020. Cigna is standing up a 24/7 customer resource center specifically dedicated to help customers with any administrative barriers related to coronavirus-related claims.
Recognizing that health outbreaks can increase feelings of stress, anxiety and sleeplessness and in some cases, loss, Cigna is also staffing a second phone line for customers. This 24-hour toll-free telephone help line will connect customers and caregivers directly with qualified clinicians who can provide support and guidance on coping and resiliency.
Any individual who suspects they may have been exposed to the coronavirus or is exhibiting symptoms should consult with their health care provider to make the appropriate testing recommendation, in line with CDC guidelines.
To mitigate exposure risks, customers are reminded that telehealth options are available for seeking on-demand medical attention, as appropriate. To access telehealth options, visit and select the “Connect Now” button on the homepage to talk with a doctor or nurse any time day or night.

Testing vs Treatment

COVID-19 testing is now generally being covered as a preventive benefit for the testing only when prescribed by an authorized physician and provided at approved laboratory locations. Other costs beyond the test (such as an associated physician office visit) will be covered based on the medical plan benefits. Best estimates for the cost of testing are approximately $50-$200 based on geographic area. This cost is similar to the cost of the flu test.

While the IRS announcement includes treatment of COVID-19, we caution employers to be thoughtful before opting to alter coverage. Currently, health carriers are not altering coverage for COVID-19 treatment, however, we have received several inquiries about doing so. We do not recommend making any changes to the medical plan benefits for treating this disease.

It is currently estimated that approximately 80% of novel coronavirus cases will be considered “mild”. The cost for treating mild cases is considered nominal with claims for office visits, urgent care/clinic, emergency room, prescriptions and monitoring. Typical prescription drug treatment for mild cases could include over the counter medication as well as prescription medications treating the accompanying symptoms. Antivirals are believed to be effective against COVID-19 but the treatment regimen is less clear currently based on antiviral availability and FDA approval.

There are significant costs associated with the treatment of serious coronavirus cases. The clinical footprint for serious cases is a progression to pneumonia or Acute Respiratory Distress Syndrome (ARDS). These patients typically require hospital or ICU stays as well as prescription drug therapy similar to the medications used to manage mild cases. The length of ICU stay is variable patient to patient with an average expected around 10 days. ARDS treatment averages 47 days of ICU care, costing up to $700,000 a month. There could also be ongoing care for seriously ill patients including dialysis. The estimated costs associated with serious cases creates potential stop-loss reinsurance exposures. If you‘d like to read more, see the article from our partner, HMIG.

Please note that the information contained in this posting is designed to provide general awareness in regard to the subject matter covered. It is not provided as legal, medical, or tax advice, nor is it intended to address all concerns in your workplace or for public health. No representation is made as to the sufficiency for your specific company’s needs. This post should be reviewed by your legal counsel or tax consultant before use.