New COVID-19 Obligations Added to Group Health Plans
The Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury released guidance for health plans this year in the form of Frequently Asked Questions (FAQ). The FAQ focuses on implementing the Families First Coronavirus Response Act (“FFCRA”), the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), and other health coverage issues related to COVID-19. In addition, the Centers for Disease Control and Prevention (CDC) released FAQs addressing who is to pay for COVID-19 vaccines.
The FAQs clarify that the legislation applies to both self-funded and fully insured employer-sponsored group health plans, including governmental plans, church plans and grandfathered plans. Coverage must be provided from March 18, 2020, until the end of the public health emergency. The FAQs specify that group health plans must cover COVID-19-related items and services as of March 18, 2020 and maintain that coverage until the public health emergency is declared over.
COVID-19 Diagnostic Testing
Here are the highlights of the tri-agency FAQ:
Requirement: Group health plans and health insurance issuers offering group or individual health insurance coverage, including grandfathered health plans, must cover certain items and services related to the testing and diagnosis of COVID-19 without cost-sharing, prior authorization or other medical management requirements. Requiring entity: FFCRA
Requirement: Providers must offer an expanded range of COVID-19 related diagnostic items and services. Requiring entity: CARES Act
Requirement: Plans must reimburse any provider of COVID-19 diagnostic testing at an amount that equals the negotiated rate. However, if the plan does not have a negotiated rate with the provider, the plan should use the cash price listed by the provider on a public website. Requiring entity: CARES Act
Requirement: An individual does not need to show the presence of symptoms or proof of a recent known or suspected exposure to COVID-19 to get a test that is covered by the plan. The test must be covered without cost sharing, prior authorization or other medical management requirements. This includes tests obtained from a state- or locality-administered site, a “drive-through” site, and/or a site that does not require appointments. However, plans are not required to cover testing for public health surveillance or employment purposes. Requiring entity: FFCRA
COVID-19 Preventive Services Coverage
Requirement: Group health plans and health insurance issuers must cover, without cost-sharing requirements, any qualifying coronavirus preventive services for an individual who has received a recommendation. Requiring entity: CARES Act
COVID-19 Vaccines
Requirement: The COVID-19 vaccination must be provided free to everyone living in the United States regardless of their immigration or health insurance status. Therefore, any provider giving vaccinations can be reimbursed for vaccine administration fees by the patient’s public or private insurance company. If someone is uninsured, the Health Resources and Services Administration’s Provider Relief Fund will cover the costs. The CDC stresses that no one can be denied a vaccine – even if they are unable to pay a vaccine administration fee. However, providers can bill for additional health care services. Requiring entity: CDC
Remember that the DOL HHS or the Treasury Department has not yet released formal guidelines, so this information is subject to change.
Copyright © 2020 Smarts Publishing
About the Author
Share This Story
Related Blogs
Fiduciary Responsibilities for Employer Health Plans: What Employers Should Know Now
When employers think about fiduciary responsibility, retirement plans often come to mind first. But recent developments make it clear that fiduciary duties also matter—sometimes significantly—when it comes to employer-sponsored health and welfare plans.
The New Era of Mental Health Parity Enforcement in 2026
Federal agencies have made mental health parity enforcement a top priority in 2026, and employers sponsoring group health plans are feeling the impact. Regulators are no longer satisfied with high‑level assurances that plans comply with the Mental Health Parity and Addiction Equity Act (MHPAEA). Instead, they expect detailed, data‑driven documentation showing that mental health and substance‑use‑disorder benefits are truly comparable to medical and surgical benefits. This includes not only the written plan design but also how rules are applied in real‑world scenarios.
The 2026 Specialty Drug Surge: What Employers Need to Prepare For
Specialty drugs have been a major cost driver for years, but 2026 marks a significant shift in both scale and urgency. With GLP 1 medications expanding into new indications, gene therapies entering the market at record pace, and oncology drugs continuing to rise in both cost and utilization, specialty medications are projected to account for more than 60% of total pharmacy spending this year. That’s a dramatic change for employers, especially considering that specialty drugs represent fewer than 5% of total prescriptions.