Rules for ACA-Mandated Preventive Services and HSA-Eligible HDHPs

TowersWatson via Benefitlink

In Notice 2013-57, the Internal Revenue Service (IRS) confirms that high-deductible health plans (HDHPs) must cover all preventive services mandated under health care reform without imposing a deductible, and grandfathered HDHPs may optionally do the same. Covering these preventive benefits and services will not jeopardize the plan’s health savings account (HSA)-qualifying status.

Background and guidance

For HSA contributions to be tax favored, the employee must be covered under an HSA-qualifying HDHP and generally may not have other health coverage, although there are some exceptions, such as vision, dental, long-term care and other HDHP coverage. For 2013 and 2014, annual deductibles in HSA-eligible HDHPs must be at least $1,250 for self-only coverage or $2,500 for family coverage, although first-dollar and low-deductible coverage is allowed for preventive care.

An IRS safe harbor exempts some preventive health services from the HSA-eligible HDHP minimum annual deductible requirements, and many of the excepted benefits are now mandated for HDHPs under the Patient Protection and Affordable Care Act (PPACA). The IRS also considers some drugs and medications as excepted preventive care, and health care reform added others.

All non-grandfathered group health plans, including HDHPs, must provide in-network coverage for mandated PPACA preventive services without participant cost sharing:

  • Evidence-based items or services that are rated “A” or “B” by the U.S. Preventive Services Task Force
  • Routine immunizations recommended by the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention
  • For infants, children and adolescents, evidence-informed preventive care and screenings in the comprehensive guidelines supported by the Health Resources and Services Administration (HRSA)
  • For women, preventive care and screenings provided in HRSA’s Women’s Preventive Services: Required Health Plan Coverage Guidelines

Notice 2013-57 clarifies that, for purposes of the HDHP/HSA rules, preventive care not subject to deductibles may include all preventive services and benefits previously defined by the IRS as well as those required under the PPACA.

Conclusion

Sponsors of HDHPs need to ensure that their plans cover all preventive services mandated under the PPACA without deductibles for participants. Sponsors of grandfathered HDHPs are free to include such benefits without cost sharing and will not lose HSA-qualifying status for doing so. Importantly, this new guidance neither requires nor prohibits the coverage of any additional preventive services.

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