Q: Can telemedicine coverage be included without cost sharing?

A: Yes.  Several states have required, and some insurance carriers have recently announced they will provide their integrated telemedicine services to plan participants without cost sharing. Self-insured plans have discretion whether they cover telemedicine without cost sharing or not.

In recognition of this fact, the CARES Act allows high deductible health plans (HDHPs) to cover telemedicine for any condition (not just COVID-19) before the deductible is met. This means employees participating in HDHPs that are offering these services can continue to contribute to the health savings accounts.  This change is only effective for HDHP plan years before January 1, 2022.

Any change in telehealth coverage should be communicated to employees/participants. Normally, if there’s a material change in plan terms mid-year that affect the content of the most recent Summary of Benefits and Coverage (“SBC”), an updated SBC must be distributed at least 60 days before the change can take effect.  However, these FAQs state that the federal government will not enforce this deadline against plans expanding telehealth for both COVID-19 and other services not related to COVID-19, with less than 60 days’ advance notice.  However, plans must provide notice as soon as they reasonably can.  This relief only applies while the COVID-19 national state of emergency or public health emergency are in effect.   Once these have been lifted, the standard rules will apply. 

Additionally, the Departments reserve the right to take enforcement action against plans that attempt to offset the cost of COVID-19 testing and treatment by raising the cost sharing, or limiting coverage of, other benefits.

Employers should review their SBC to see if changes are necessary.  Even if they are not, employers will want to communicate any changes to their covered employees and dependents as soon as they reasonably can.

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