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Agencies Provide Additional Guidance on Health Plan Coverage of OTC COVID-19 Tests

As we previously reported, the Departments of Labor (DOL), the Treasury, and Health and Human Services (HHS) released guidance on January 10, 2022 regarding group health plan coverage of over the counter COVID-19 tests (OTC tests).

As of January 15, 2022, insurance companies and health plans are required to cover eight free OTC tests per covered individual per month. That means a family of four, all on the same plan, would be able to get up to 32 of these tests covered by their health plan per month.

To further assist employers and plan participants the agencies issued additional guidance on February 4, 2022 via a series of new series of frequently asked questions (FAQs). The updated guidance addresses the following:

  • Limiting covered to preferred pharmacies and other retailers
  • Difficulties in direct access to OTC tests related to supply shortages
  • Limiting the number of OTC tests and prevention of fraud and abuse
  • The impact on FSAs, HRAs, and HSAs

Next Steps for Employers

Employers are also strongly encouraged to review the interagency guidance to ensure their group health plan is in compliance.

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