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IRS Expands Preventative Care Benefits Permitted to be Provided by HDHPs

 July 18 2019     Diane Cross
In response to President Trump’s recent executive order, the Treasury Department and the IRS expanded the list of allowable preventive care benefits that can be provided by a high deductible health plan (HDHP) before the deductible is met without impacting HSA eligibility. This welcomed guidance, effective immediately, provides much need clarity for employers, insurers, consultants and other service providers – especially those employing strategies to increase wellness and medication compliance in at-risk employee populations.

Background
To be a qualifying HDHP for purposes of Health Savings Account (HSA) eligibility, an HDHP cannot provide benefits – except for preventive care – until the minimum deductible for that year is met. Generally, preventive care does not include services or benefits intended to treat existing illnesses, injuries, or conditions. President Trump’s recent executive order directed federal agencies to expand the rules to allow HDHPs to include coverage before the deductible is met for medical care that helps maintain health status for individuals with chronic conditions, and still be compatible with HSAs (see our recent blog post). Per Notice 2019-45, additional medical care services received, and items purchased (e.g. prescription drugs), for certain chronic conditions (listed below) are now classified as preventive care for an individual with such chronic condition.

Expanded Preventative Care Benefits
To prevent exacerbating certain conditions (or developing secondary conditions), the following services now qualify as preventive care* when prescribed for the related chronic condition/diagnosis listed:

Preventive Care for Specified Conditions

For Individuals Diagnosed with

Angiotensin Converting Enzyme (ACE) inhibitors

Congestive heart failure, diabetes, and/or coronary artery disease

Anti-resorptive therapy

Osteoporosis and/or osteopenia

Beta-blockers

Congestive heart failure and/or coronary artery disease

Blood pressure monitor

Hypertension

Inhaled corticosteroids

Asthma

Insulin and other glucose lowering agents

Diabetes

Retinopathy screening

Diabetes

Peak flow meter

Asthma

Glucometer

Diabetes

Hemoglobin A1c testing

Diabetes

International Normalized Ratio (INR) testing

Liver disease and/or bleeding disorders

Low-density Lipoprotein (LDL) testing

Heart disease

Selective Serotonin Reuptake Inhibitors (SSRIs)

Depression

Statins

Heart disease and/or diabetes


However, this does not mean that a plan can blanket consider these services preventive care. These services will only be considered preventive when provided in conjunction with the above medical diagnoses. When prescribed under other circumstances, the benefits remain subject to the general HSA rules regarding preventive care.

Impact
As mentioned above, this guidance is effective immediately (as of July 17, 2019). The guidance does not require employers offering HDHPs to expand the definition of preventive care or the list of services it covers at low or no cost, but it allows employers and insurers to do so and remain HSA qualified. For employers who wish to add these preventive services to their HDHPs, for practical purposes, they will most likely have to wait until their next renewal. Please contact your HORAN representative with any questions.


*Notice 2019-45 explains that it does not impact health care reform’s definition of preventive care or the status of any medical care previously recognized as preventive care.