In the most recent sign that special COVID-19 benefit plan rules are drawing to a close, last Friday, the IRS issued Notice 2023-37, which clarifies the scope of COVID-19 testing and treatment that can be provided on a pre-deductible basis under a high deductible health plan (HDHP) without impacting a participant’s ability to contribute to a health savings account (HSA). As a reminder, if an HDHP covers medical items and services before the participant satisfies the IRS minimum deductible (self-only or family), that coverage may disqualify the participant’s HSA contributions. Notice 2023-37 can be downloaded here.
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Update: Big Headline, Small Impact – Legislation Ends COVID-19 National Emergency
Important Update: Based on informal comments from the U.S. Department of Labor, it appears that the tolling of benefit plan deadlines will end on July 10, 2023, as described in our earlier blog on this subject, notwithstanding the legislation that was signed on Monday ending the COVID-19 National Emergency on April 10th…
It’s Over: DOL, Treasury, and HHS Confirm End of (Most) COVID-19 Rules for Health Plans
Update: On April 10, 2023, President Biden signed into law legislation ending the COVID-19 National Emergency prior to the previously announced May 11, 2023 date. See our blog on this new development here. The legislation does not impact the end of the COVID-19 Public Health Emergency.
Earlier this week, the Departments of Labor, Treasury,…
The Long-Awaited End of the Tolling of Plan Deadlines due to COVID-19
The Biden Administration recently announced that the COVID-19 National Emergency will end on May 11, 2023. This means that the requirement to extend various benefit plan deadlines due to the COVID-19 pandemic will end as well.
By way of brief background, early during the pandemic, the U.S. Departments of Labor and Treasury adopted relief pursuant…