What You Need to Know About COVID Test Kit Rules for Group Health Plans

Starting Jan. 15, the nation's health insurers have been required to cover the cost of up to eight at-home rapid COVID-19 tests per month for their health plan enrollees.

Insurers are taking different approaches to the mandate and, as an employer, you should communicate with your covered staff about this new benefit, how it works and other advice.

According to frequently asked questions posted by the Department of Labor, coverage for over-the-counter test kits must be covered by insurers without cost-sharing and without a doctor's order or prescription. It laid out a series of rules insurers and health plans must follow. They:

• May require enrollees to submit reimbursement claims for OTC COVID-19 tests (the agency, however, "strongly encourages" plans to reimburse pharmacies directly instead).
• Must reimburse plan enrollees for tests they purchase outside of their preferred network up to $12 per test if they also offer coverage for OTC tests through a pharmacy network. Health plans are authorized to provide a more generous reimbursement from tests purchased through a non-preferred provider.
• Can limit the number of OTC tests covered without cost-sharing, as long as they cover eight per month per enrollee with no cost-sharing. That means a family of three on a family plan can be reimbursed for up to 24 tests per month.
• Cannot limit the number of covered tests if they are ordered by a doctor after a clinical assessment.
• Can require enrollees to attest that OTC tests they are reimbursed for are for personal use and not for work, that they are not being reimbursed for the tests by other sources and that they won't resell the tests.
• Can require that enrollees provide receipts as proof of purchase.

Action items

Contact us or your group health insurer for guidance on how it will handle payment for OTC tests. It is important to:

• Check that it has pharmacy and retailer networks in place where covered individuals can obtain the OTC tests.
  
• Check if it has a direct-to-consumer shipping program for kits.
  
• Check if it has systems in place to handle claims and for reimbursing either participants or participating pharmacies that have point-of-sale test kits available.
  
• Ask the insurer whether it has any purchase or reimbursement limits if tests are purchased at a non-network pharmacy or retailer.

 
Once you have those details in hand, hold a meeting with your staff covering the following:

• An explanation of the new benefit and how their insurer will reimburse or pay for the kits.
  
• Go over the claims and reimbursement process if they pay out of pocket at a non-participating pharmacy.
• Provide a list of network pharmacies and retailers that will offer point-of-sale test kits that the insurer pays for direct. Also provide information on any direct-to-consumer purchase options.
• Tell them about any reimbursement limits if they purchase from non-preferred pharmacies, or other limits (like the eight tests per month limit).
• Advise your staff to keep receipts for any at-home test kits they have purchased since Jan. 15. They should also save the boxes the test kits come in as some plans may require them as proof of purchase.