Covid-19 Testing Coverage Mandate Expanded

Earlier this week, the COVID-19 testing coverage mandate was significantly expanded pursuant to FAQs issued jointly by the Departments of Labor, Health and Human Services and the Treasury (collectively, the Departments).  The newly expanded mandate is effective now - or more precisely, on January 15, 2022. Following is a discussion of what is required by group health plans (and health insurance issuers) and certain procedural issues with respect to the guidance.

Background: Way back, when the long fingers of COVID-19 began to reach across the country, legislation was enacted to expand access to COVID-19 testing through group health plans.  Specifically, the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief and Economic Security Act (CARES Act) required that health plans cover certain COVID-19 tests with no cost sharing and no prior authorization requirements for the duration of the COVID-19 public health emergency declared by the