In response to questions regarding expenses related to testing and treatment of the coronavirus (COVID-19), the IRS recently issued Notice 2020-15 to provide guidance on the impact of health plan coverage of testing and treatment of COVID-19 with regard to health savings account eligibility, given that to be eligible to contribute to an HSA, an individual must only be covered by a high deductible health plan (HDHP).   

The Notice provides that, until further guidance is issued, a health plan that otherwise satisfies the requirements to be a HDHP will not fail to be an HDHP merely because the health plan provides health benefits associated with testing for and treatment of COVID-19 without a deductible, or with a deductible below the minimum deductible (self only or family) for an HDHP.  

Consequently, individuals covered by health plans that provide for such testing and treatment of COVID-19 below the deductible will continue to be eligible to contribute to an HSA.  This notice should answer many questions regarding the impact of this more expansive coverage on HSA eligibility.