Covid-19 and Health Savings Account Health Insurance Questions & Answers

Frequently Asked Questions & Answers

Question: If an employer is sponsoring a qualified High Deductible Health Plan ("HDHP") with a Health Savings Account ("HSA"), will providing coverage for testing for, or treatment of, COVID-19 disqualify covered individuals from HSA eligibility?

Answer: No. Under IRS Notice 2020-15, it is clear that providing coverage for testing for, or treatment of, COVID-19 with no cost sharing and prior to satisfaction of the minimum required statutory deductible, will not disqualify an individual from eligibility to open and contribute to an HSA.

Question : Under the CARES Act, telehealth and other remote services can be provided by an HDHP prior to satisfaction of the deductible without jeopardizing HSA eligibility of covered individuals. However, the relief is temporary. When does the relief expire?

The relief expires for plan years that begin on or after December 31, 2021.

For example, for a calendar year HDHP, this relief applies as follows:

• January 1, 2020 – December 31, 2020 plan year, and
• January 1, 2021 – December 31, 2021 plan year.

In this example, the relief would no longer be available effective with the January 1, 2022 plan year.

Have any other questions, comments or concerns? Feel free to reach out to us at Total Benefit Solutions, Inc (215)355-2121