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Latest Insights on COVID-19

close up of a coronavirus molecule

Latest Insights on COVID-19

Corporate Benefits

Congressional Research Service Issues COVID-19 and Private Insurance FAQs

September 01, 2020

On August 24, 2020, the Congressional Research Service (CRS) issued COVID-19 and Private Health Insurance Coverage: Frequently Asked Questions in light of the ongoing pandemic. With private health insurance being the primary source of health coverage in the US, the FAQ addresses covered benefits and cost sharing regarding COVID-19 testing, treatment, and a potential vaccine under private health insurance (which includes employer-sponsored group health plans generally and individual market plans).

The FAQ reiterates that under the Families First Coronavirus Response Act (FFCRA) and Coronavirus Aid, Relief and Economic Securities Act (CARES Act), most private health insurance plans are required to cover COVID-19 testing without cost sharing (both in network and out of network), including test administration and related items and services. Further, there is not a federal requirement specifically for the coverage of COVID-19 treatment. However, there is a federal requirement for certain plans to cover a core set of categories for essential health benefits (EHB), and each state can select its EHB benchmark plan. That said, the EHB benchmark plans in all states currently provide coverage for the diagnosis of and treatment for COVID-19. However, the specific benefits provided may vary by state and by plan. Importantly, even if a coverage requirement exists, cost sharing may still apply.

Additionally, the FAQ explains that while there currently is no FDA-approved COVID-19 vaccine available, the CARES Act requires most plans to cover such vaccine (when available) with no cost sharing, if recommended by the Advisory Committee on Immunization Practices (ACIP). Likewise, coverage (without cost sharing) is required by most plans for other COVID-19 preventive services that are recommended by the United States Preventative Services Task Force (USPSTF). The FAQ also provides additional information on covered benefits and cost sharing regarding COVID-19 related services under private health insurance.

While the FAQ does not introduce any new guidance, employers should be aware of the COVID-19 coverage and cost sharing requirements as outlined in this report. 

COVID-19 and Private Health Insurance Coverage: Frequently Asked Questions