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IRS Issues Guidance Relating to High Deductible Health Plans and Coronavirus Testing

Client Alert
March 12, 2020

In response to the Coronavirus/COVID-19 pandemic, the IRS has released guidance in Notice 2020-15 relating to the testing and treatment for individuals covered by a High Deductible Health Plan (HDHP).

Under normal circumstances, an HDHP will fail to satisfy the requirements of an HDHP if it provides coverage for testing or treatment before the annual minimum deductible has been met (subject to certain enumerated well-known exceptions for wellness and preventative care). A plan disqualification would prohibit participants in the HDHP from making contributions to their Health Savings Account as HSAs require coverage by an HDHP.

The Notice provides that an HDHP will not fail to qualify as an HDHP “merely because the health plan provides medical care services and items purchased related to testing for and treatment of COVID-19 prior to the satisfaction of the applicable minimum deductible.” As a result, the fact that an individual is covered by an HDHP will not be impacted by free or reduced charges for testing and treatment of Coronavirus/COVID-19, regardless of whether or not they have met the deductible requirements under the HDHP.

While the IRS has chosen to provide this relief for both HDHPs and those individuals who receive their coverage through such a plan, this announcement has no impact on whether or not an insurance carrier will take any action regarding coverage for these items. Please contact your insurance carrier to determine what, if any, accommodation or arrangement they are making in light of the pandemic.

For questions on this topic or any other tax-related questions for your business, please contact Priscilla Grant at (330) 253-5934 or pagrant@bmdllc.com.

HDHPHigh Deductible Health Plancorona virusirsinsurancePriscilla Grant
Client Alert

Stimulus Package Recap - What The CARES Act Means for You, Your Employees & Your Business

March 30, 2020As BMD's Business Crisis Response Team shared in its report this weekend, the Stimulus package was passed by both the Senate and House this week. Phase III of the ‘‘Coronavirus Aid, Relief, and Economic Security Act’’ or the ‘‘CARES Act,’’ offers $2 trillion in economic relief to individuals and businesses affected by the Coronavirus epidemic. We identified the most significant areas of the bill that could impact or benefit your business.Client Alert

Governor DeWine Signs Bill Tolling Statutes of Limitations During COVID-19 Emergency Period

March 27, 2020During his March 27, 2020 press conference on Ohio’s ongoing efforts to respond to COVID-19, Governor Mike DeWine officially signed House Bill 197 into law. HB 197, which passed the Ohio House and Senate with unanimous bipartisan support, contains important provisions affecting the legal rights of litigants whose claims may be subject to the statutes of limitations enacted under the Ohio Revised Code.Client Alert

Is Insurance Available for Coronavirus Losses?

March 27, 2020The shutdown of non-essential businesses in Ohio and other states, as well as the economic impacts caused by the coronavirus, are forcing businesses to evaluate all options to keep their doors open and their staff employed. Many businesses are asking whether their insurance policies provide for the recovery of lost business income and expenses due to the coronavirus.Client Alert

Exempt Organizations: Form 990s Due May 15 Have Not Been Extended

March 27, 2020Although the IRS has automatically postponed the filing and payment deadline from April 15, 2020 until July 15, 2020 for most taxpayer returns, the IRS notice specifically does not apply to any Federal informational return.Client Alert

UPDATE: COVID-19 Considerations for the Construction Industry

March 26, 2020The implications of COVID-19 for the construction industry are significant and rapidly evolving, since Governor Mike DeWine instructed Ohioans to “stay at home” via Order (the “Order”) effective March 23, 2020.
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