Can I use my health savings account (HSA) to pay for COVID testing and treatment?
Yes, you can use your HSA to pay for COVID testing and treatment costs that you pay out-of-pocket. For the most part, your health insurance (including high-deductible health plans) should cover the cost of COVID-19 vaccinations, which means you won’t have out-of-pocket costs for that.
But if you need treatment for COVID, you’ll likely need to pay your plan’s normal cost-sharing. And health plans no longer have to pay for COVID testing now that the public health emergency has ended, which means you will likely have out-of-pocket costs for PCR and at-home COVID tests. You can use your HSA funds to cover those out-of-pocket costs if you choose to do so.
IRS relaxed HDHP rules to address COVID testing and treatment
With the exception of preventive care, high-deductible health plans normally cannot pay for any medical services until the insured has met at least the minimum deductible set by the IRS. But in the face of the COVID pandemic, those rules were relaxed.
In March 2020, the IRS announced that HSA-qualified health plans would be allowed to pay for COVID-19 testing and treatment before the enrollee had met their deductible, without the health plan losing its HSA-qualified status. That guidance was expanded later in 2020 to clarify that a full testing panel, including flu, norovirus, and RSV, could be covered without the plan using its HDHP status.
But the IRS has issued updated guidance to clarify that this flexibility continues only through the end of 2024. After that, a plan that covers COVID testing or treatment before the minimum HDHP deductible is met would fail to be an HDHP.
Coverage of COVID testing and vaccines
For the duration of the COVID public health emergency, which ended May 11, 2023, the federal government and numerous states required health plans — including HDHPs — to cover COVID testing with no cost-sharing, which meant the insured didn’t have to pay anything for the service (this included up to eight at-home COVID tests per member per month). But that ended with the end of the public health emergency: Health plans no longer have to cover at-home COVID tests, and can require their regular cost-sharing for PCR tests.
As noted above, a health plan can still be considered an HDHP even if it covers COVID testing pre-deductible, but only through 2024.
COVID vaccines still have to be covered at no cost to the enrollee — that did not change with the end of the public health emergency, and it applies to all non-grandfathered health plans, including HDHPs. But now that the public health emergency has ended, health plans can require their members to use in-network providers when obtaining vaccines.
Cost-sharing for treatment of COVID-19
Although the IRS allowed HDHPs to cover COVID treatment without a deductible, the federal government never required health plans to cover COVID treatment without cost-sharing, and neither did most states (keeping in mind that treatment is not the same thing as testing and vaccinations; testing had to be covered without cost-sharing during the pubic health emergency, and vaccines still have to be covered without cost-sharing).
Some health plans – including some HDHPs – opted to waive cost-sharing for COVID treatment in 2020, but this had mostly ended by 2021, once COVID vaccinations became widely available. If you get COVID and need treatment, you should generally expect to have to meet your plan’s regular cost-sharing obligations.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health insurance marketplace updates are regularly cited by media who cover health reform and by other health insurance experts.
