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The End of "Free" COVID-19 Tests? Preventive Care?

Now that we're at the end of the COVID public health emergency (PHE), employer-sponsored group health plans are no longer required to pay for diagnostic COVID-19 tests without cost-sharing requirements or prior authorization or other medical management. The DOL is "encouraging" this coverage to be offered, despite it not being required. The end of the PHE does NOT impact the requirement to cover COVID-19 vaccines (and their administration) without cost-sharing. 

Litigation in Texas (currently being appealed by the DOL) has also brought into question whether/how plans will be required to cover a wider swatch of preventive services moving forward.  

It is our expectation that the vast majority plans will likely retain "status quo" through the end of the current year; however, with health plan renewal costs increasing for most employers each year, it remains to be seen what potential "cost savings" efforts might be investigated in the post-PHE era...

"Any plan or issuer that provides coverage for COVID-19 diagnostic testing furnished after the PHE ends, including over-the-counter (OTC) COVID-19 diagnostic tests purchased after the PHE ends, is not prohibited from imposing cost-sharing requirements, prior authorization, or other medical management requirements for those items and services under section 6001 of the FFCRA. However, plans and issuers are encouraged to continue to provide this coverage, without imposing cost sharing or medical management requirements, after the PHE ends..."

Tags

covid-19 tests, covid-19 vaccines, phe, public health emergency, l&e