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Health Law Monitor

FAQs Clarify Health Plan’s Obligation to Cover COVID-19 Testing

June 23, 2020

By: Jill E. Hall

The Departments of Labor, Health and Human Services and the Treasury issued a new set of Frequently Asked Questions today to provide guidance on the Families First Coronavirus Relief Act (“FFCRA”), the Coronavirus Aid, Relief and Economic Security (CARES) Act and other health coverage issues related to COVID-19. The FAQs can be found here.

Section 6001 of FFCRA requires health plans, including both fully insured and self-funded employer-sponsored health plans, to cover items or services related to COVID-19 diagnostic testing. Such items and services must be covered without imposing prior authorization or cost-sharing requirements, including deductibles, co-payments and coinsurance. Today’s FAQs answer some important questions employer plan sponsors have been grappling with regarding the mandate that testing for COVID-19 be covered with no cost-sharing requirements, including three questions highlighted below.

  1. Are plans required to cover at-home testing for COVID-19?

Yes. At-home COVID-19 testing must be covered when ordered by an attending healthcare provider who has determined the test is medically appropriate.

  1. Are plans required to cover COVID-19 testing for employment purposes?

No. Section 6001 of FFCRA requires coverage for items and services only for diagnostic purposes. FFCRA does not require coverage for testing conducted to screen for general workplace safety or other purpose not primarily intended for diagnosis or treatment.

  1. Must plans cover multiple diagnostic tests?

Yes. The coverage requirement is not limited with respect to the number of tests as long as the tests are medically appropriate as determined by the attending healthcare provider.


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