FAQs Clarifying COVID-19 Testing & Vaccine Coverage

The constant influx of information and everchanging compliance updates surrounding the coronavirus pandemic can be overwhelming, making it strenuous to comprehend how up-to-date guidance and coverage affects one’s organization and employees.

In response, the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury have issued Frequently Asked Questions (FAQs) and guidance to clarify health coverage requirements related to COVID-19. The FAQs address specific COVID-19 diagnostic items and services that health plans and issuers must cover, without cost-sharing. The FAQs explain that plans and issuers:

  • May not use medical screening criteria to deny (or impose cost sharing on) a claim for COVID-19 diagnostic testing for an asymptomatic person with no known or suspected exposure to COVID-19.
  • May distinguish between COVID-19 diagnostic testing of asymptomatic people that must be covered, and testing for general workplace health and safety or other purposes not primarily intended for individualized diagnosis or treatment of COVID-19.
  • Must assume that a test is for individualized clinical assessment if it is provided by a licensed or authorized provider, including at a state- or locality-administered site, a drive-through site, or a site that does not require appointments.

Additional guidance provided by the FAQs include:

  • Coverage of COVID-19 vaccines and other preventive care services;
  • Notice requirements for plans and issuers regarding coverage of preventive care services; and
  • Requirements for employee assistance programs (EAPs) and on-site medical clinics that administer COVID-19 vaccines to be considered excepted benefits.

Employers are encouraged to monitor updates from their state departments of labor for new laws, rules and guidance surrounding coverage of COVID-19 diagnostic testing; as well as ensure communication surrounding the circumstances in which testing is covered is clear. Notice of preventive care coverage changes is required as soon as reasonably practicable.

For additional guidance, click here.


Should you have any questions regarding this information, please contact the Creative Benefits, Inc. Team at 866-306-0200 or solutions@creativebenefitsinc.com.