The guidance—in the form of frequently asked questions
(FAQs)—further interprets testing requirements that
originally appeared in the
Families First Coronavirus Response Act (FFCRA) and that were
expanded in the
Coronavirus Aid, Relief, and Economic Security (CARES) Act.
The FFCRA requires group health plans to cover U.S. Food and
Drug Administration (FDA)-approved COVID-19 tests and services
related to the furnishing or administration of the tests on a
first-dollar basis, meaning before a participant's deductible
is met and without requiring any other cost-sharing such as
copayments or coinsurance. In addition, plans may not impose
medical management requirements such as prior authorization on
tests and related services. These requirements took effect March
18, 2020, and end when the
national emergency period ends. The CARES Act later expanded
the scope of covered COVID-19 tests to include tests:
