On February 24, 2023, Juliana Reno was quoted regarding President Joe Biden’s recent announcement that federal public health and national emergency designations tied to the coronavirus pandemic will be ending this summer.
According to the article, the administration announced that two federal emergency designations would be ending on May 11, 2023. A major consequence of the HHS public health emergency designation lifting is that group health plans no longer have to cover things like COVID tests without cost-sharing or prior authorization.
Reno said two major considerations are at the forefront for many employers on COVID testing benefit changes: "One is policy, and the other is cost. And by policy, I mean, what message are you sending to your employees?"
"Do you want to be the kind of employer that covers a lot of the costs of over-the-counter COVID tests, because that's something your employees need?" Reno said, noting she's heard other employers citing costs concerns who elect not to continue coverage.
Reno said more broadly, "Employers are looking forward to no longer having to pay the list price for out-of-network COVID tests. They don't have to cover them, and if they cover them, they don't have to pay full price. That's the big thing for employers, I think."
That's because the IRS put out guidance in 2020 that assured administrators of high-deductible plans that COVID testing and treatment expenses outside the deductible wouldn't affect tax qualifications, citing the public health emergency, "until further guidance is issued."
"Sometime between now and May 11, I would expect the IRS is going to say, here's when this is sunset. What we really don't know is how long a tail they are going to let plans have," Reno said, referring to the exact date those expenses can no longer be paid by the plan pre-deductible.