Insights

On March 18, 2020, CMS provided a set of FAQs that discusses the coverage of COVID-19 treatment in catastrophic plans. As background, insurers are generally not permitted to modify the health insurance coverage for a product midyear.

The FAQs address two questions:

• Question and Answer 1 confirms that catastrophic plans must cover essential health benefits (EHB), such as the diagnosis and treatment of COVID-19. However, this coverage is subject to certain limitations, and can vary by plan. A catastrophic plan may not provide coverage of EHB before an enrollee meets their catastrophic plan deductible for that applicable plan year, except as follows: 1) a catastrophic plan must provide coverage for at least three primary care visits per year before reaching the deductible, and 2) in accordance with section 2713 of the Public Health Service Act (PHS Act), a catastrophic plan may not impose any cost-sharing requirements (such as a copayment, coinsurance or deductible) for preventive services.
• Question and Answer 2 confirms that HHS will not take enforcement action against any health insurance issuer that amends its catastrophic plans to provide pre-deductible coverage for services associated with the diagnosis and/or treatment of COVID-19, and encourages states to follow suit.

Employers should consider this guidance as they provide coverage to participants who may be diagnosed with and treated for COVID-19.

FAQs on Catastrophic Plan Coverage and COVID-19 »