On March 11, 2020, the IRS issued Notice 2020-15, to address an
important coronavirus issue for high-deductible health plans that
are coordinated with health savings accounts ("HSAs").
The guidance paves the way for health plans to waive or reduce
deductibles for any "medical care services and items purchased
relating to testing for and treatment of COVID-19," without
affecting eligibility to make HSA contributions.
In general, employees may make and receive contributions to HSAs
only if they are enrolled in a "high deductible" health
plan. With limited exceptions, covering medical expenses before the
minimum deductible is reached would make employees ineligible to
make or receive HSA contributions, and would subject employees who
have made HSA contributions to an excise tax. The HSA rules
generally have an exception for "preventive" care, but
not for services and items purchased to treat a disease.