As federal and state governments respond to COVID-19, employers and plan fiduciaries must also address the evolving issues arising under employer-sponsored health plans. We expand on the following topics in this update:

  • HIPAA limitations must be followed; however, the public threat posed by COVID-19 may permit or require certain disclosures
  • As of March 18, 2020, all participants in employer-sponsored health plans may receive diagnostic testing for COVID-19 at no cost to the participant
  • Payment for COVID-19 testing and treatment below the minimum deductible will not disqualify a high deductible health plan, and participants may continue to contribute to a health savings account
  • Testing and treatment for COVID-19 are generally considered essential health benefits

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