Agencies issue clarifying guidance on coverage of over-the-counter COVID-19 tests

On Jan. 10, 2022, the Departments of Labor, Health and Human Services (HHS), and the Treasury issued guidance clarifying the requirements for group health plans and health insurance issuers to cover the costs of over-the-counter (OTC) COVID-19 diagnostic tests. Plans and issuers must cover the costs of COVID-19 tests during the COVID-19 public health emergency without imposing any cost-sharing requirements, prior authorization, or other medical management requirements.

In this bulletin, we provide an overview of the guidance on coverage of OTC COVID-19 tests, including legal requirements, important dates, and the limits plans and insurance issuers may implement on coverage. Employers should carefully review this information, as well as OSHA’s vaccination and testing mandate, and consider how this may impact their business.