IRS Expands Preventive Care Benefits That Are Not Subject to HDHP Deductibles

A new IRS notice expands the list of preventive care benefits that may be covered by a high deductible health plan (HDHP) without a deductible, or with a deductible below the minimum deductible for an HDHP. Except for preventive care benefits, an HDHP can pay for benefits only after the deductible has been reached.

Pursuant to an executive order, a the notice will allow individuals with certain conditions, such as asthma or diabetes, to obtain coverage for treatments and medications, such as inhalers and insulin, without first meeting their high deductible.

HDHPs require covered individuals to pay all medical costs, except for preventive care, until the deductible is met. An individual must be covered by a HDHP and have no disqualifying health coverage to be eligible to use a health savings account.

In IRS Notice 2019-45, which was effective July 17, 2019, the Treasury Department and the Internal Revenue Service expanded the preventive care HDHPs may cover to include certain treatments for chronic illnesses. The IRS and Treasury used the following criteria to determine whether a treatment was preventive care:

  • the medical service or item is low-cost;
  • there is medical evidence supporting high cost efficiency of preventing exacerbation of the chronic condition or the development of a secondary condition; and
  • there is a strong likelihood, documented by clinical evidence, that with respect to the class of individuals prescribed the item or service, the specific service or use of the item will prevent the exacerbation of the chronic condition or the development of a secondary condition that requires significantly higher cost treatments.
Preventive care for specified conditions For individuals diagnosed with
Angiotensin Converting Enzyme (ACE) inhibitors Congestive heart failure, diabetes, and/or coronary artery disease
Anti-resorptive therapy Osteoporosis and/or osteopenia
Beta-blockers Congestive heart failure and/or coronary artery disease
Blood pressure monitor Hypertension
Inhaled corticosteroids Asthma
Insulin and other glucose-lowering agents Diabetes
Retinopathy screening Diabetes
Peak flow meter Asthma
Glucometer Diabetes
Hemoglobin A1c testing Diabetes
International Normalized Ratio (INR) testing Liver disease and/or bleeding disorders
Low-density Lipoprotein (LDL) testing Heart disease
Selective Serotonin Reuptake Inhibitors (SSRIs) Depression
Statins Heart disease and/or diabetes

The notice does not mandate that HDHPs cover the treatments as preventive care. Sponsors of HDHPs can choose whether they want to classify the treatments as preventive care that can be covered prior to an individual meeting his or her deductible.

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