January 13, 2020
Recently, the Internal Revenue Service (IRS) issued Notice 2019-45, which permits (but does not require) HSA/HDHP arrangements to cover certain chronic condition treatments before participants satisfy their deductibles. Below are details that will be relevant to plan sponsors.
Notice 2019-45, provides that HDHPs paired with HSAs can reimburse the following chronic condition treatments, provided they are prescribed for their corresponding conditions:
HSA/HDHPs and Chronic Condition Treatments
|Preventive Care for Specific Conditions||For Individuals Diagnosed with|
|Angiotensin Converting Enzyme (ACE) inhibitors||Congestive heart failure, diabetes, and/or coronary artery disease|
|Anti-resoprtive therapy||Osteoporosis and/or osteopenia|
|Beta-blockers||Congestive heart failure and/or coronary artery disease|
|Blood pressure monitor||Hypertension|
|Insulin and other glucose lowering agents||Diabetes|
|Peak flow meter||Asthma|
|Hemoglobin A1c testing||Diabetes|
|International Normalized Ratio (INR) testing||Liver disease and/or bleeding disorders|
|Low-density Lipoprotein (LDL) testing||Heart disease|
|Selective Sertonin Reuptake Inhibitors (SSRIs)||Depression|
|Statins||Heart disease and/or diabetes|
Plan sponsors interested in implementing this pre-deductible coverage should note the following:
- The chronic condition treatments listed above are the only ones currently permitted under the HSA rules. The IRS will review and update this list approximately every 5-10 years and will continue considering standards for preventive care.
- HSA/HDHP arrangements can continue providing pre-deductible coverage for current preventive items/services such as annual well visits and immunizations.
- HSA/HDHP arrangements generally can require cost-sharing for the above items/services but cannot require cost-sharing if they overlap with ACA preventive services such as statins.