Notice 2020-15: High-deductible health plans, expenses related to coronavirus (COVID-19)

High-deductible health plans, coronavirus

The IRS today released an advance version of Notice 2020-15 as guidance allowing individual taxpayers with high-deductible health plans to receive testing and treatment related to the novel coronavirus (COVID-19) without jeopardizing the status of these health plans.


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Notice 2020-15 [PDF 38 KB] provides guidance for individuals with a high-deductible health plan (HDHP) under section 223(c)(2)(A), and HDHPs that cover the cost of testing and treatment related to COVID-19. The notice also clarifies that an individual covered by the HDHP will not be disqualified from being an eligible individual under section 223(c)(1) who may make tax-favored contributions to a health savings account (HSA).

As further explained in a related IRS release—IR-2020-54—health plans that otherwise qualify as HDHPs will not lose that status merely because they cover the cost of testing for or treatment of COVID-19 before plan deductibles have been met. As the IRS noted, any vaccination costs continue to count as preventive care and can be paid for by an HDHP.

Today’s notice applies only to HSA-eligible high-deductible health plans. The IRS release directs employees and other taxpayers in any other type of health plan with questions about their own plan and its coverage to contact their health plan.

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