Participants should refrain from using their account-based plans from paying for OTC tests upfront and then seeking reimbursement from their health plan.
To ring in the New Year, President Biden announced a new rule requiring group health plans to cover over-the-counter (OTC) COVID-19 tests with no cost-share to plan participants. This rule, implemented by additional guidance by the Department of Labor (DOL), significantly expanded the initial mandate to cover COVID-19 testing with no cost-sharing under the Families First Coronavirus Response Act (FFCRA).
Under the new rule, group health plans may provide direct coverage for OTC COVID-19 tests (the plan pays the provider of the test directly) or, in the alternative; participants may pay for the test upfront and then seek reimbursement from the group health plan. The upfront payment approach here may be unfamiliar for many plan participants who have never had to pay for their medical expenses upfront and seek reimbursement.
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