Coronavirus Aid, Relief, and Economic Security (CARES) Act Updates

Relating To Health Coverage

Testing

Legislation through the CARES Act builds upon The Families First Coronavirus Response Act (FFCRA) by requiring health insurance plans to cover costs associated with COVID -19 testing beyond the tests approved by the FDA including lab and state developed tests and health and human service approved testing.

Health insurance plans are also required to pay for testing administered by an out-of-network provider based on the providers “cash price”. During the public health emergency, cash prices must be publicly available. While the CARES Act requires health insurance plans to cover the cost of out-of-network COVID-19 testing, employees are recommended to seek testing through an in-network provider.

Over-The-Counter Medications

Over-the counter medications without a prescription and menstrual products are now considered qualified medical expenses eligible for payment through HSAs and FSAs and reimbursement through some HRAs. The CARES Act revokes previous ACA guidelines stating that over-the-counter medications without a prescription were not a qualifying medical expense. This provision of the act is retroactive to qualifying medical expenses purchased after December 31, 2019.

Telehealth

Under the CARES Act, pre-deductible telehealth is available to group health plan members with HSAs attached to High Deductible Health Plans (HDHPs) that began on or before December 31, 2021 without violating federal guidelines regarding the use of HDHPs and HSAs.

Vaccines and Preventive Care

When a COVID-19 vaccine is developed, the CARES Act guarantees there will be no cost share associated with receiving the vaccine. The COVID-19 vaccine’s “minimum interval” period will be expedited to 15 days after being recommended by The U.S. Preventive Services Task Force (USPSTF) and The Advisory Committee on Immunization Practices (ACIP). Typical “minimum interval” periods last one year after USPSTF and ACIP recommendations.