In order to remove barriers for testing and treatment of the coronavirus (COVID-19), on March 11, 2020, the Internal Revenue Service (IRS) issued Notice 2020-15
(the Notice), which states that until further guidance is issued, high deductible health plans (HDHPs) may provide testing and treatment of COVID-19 without a deductible or with a deductible below the applicable HDHP minimum deductible (self only or family). Such COVID-19 coverage will not disqualify the health plan from HDHP status. As a result, individuals covered by an HDHP that provides COVID-19 health benefits with reduced or no cost sharing will not be disqualified from eligibility to make or receive tax-favored contributions to a health savings account. In addition, the IRS noted that it continues to consider vaccinations (such as a vaccination that may be developed relating to COVID-19) to be preventive care eligible for first dollar coverage under an HDHP with no cost sharing.