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In June, the Departments of Labor, Treasury, and Health and Human Services jointly issued a new set of FAQs further clarifying requirements regarding coverage of COVID-19 testing. Under the Families First Coronavirus Relief Act and the CARES Act, plans are generally required to fully cover COVID-19 testing with no cost to the participant. These FAQs further explore what type of testing is covered under the Acts.
The FAQs emphasize that testing is only required to be covered when tests are diagnostic and medically appropriate for the individual, as determined by an attending health care provider. Therefore, an at-home COVID-19 test must be fully covered by the health plan as long as the test is ordered by a health provider who has determined that the test is medically appropriate. Likewise, multiple COVID-19 tests for the same participant must be fully covered as long as each test was determined to be medically appropriate. In contrast, COVID-19 testing for the purpose of general public health surveillance or for workplace health and safety (such as requiring an employee to test before returning to work) is outside of the scope of the Acts and is not required to be fully covered by health plans.