Guidance on no-cost at-home COVID-19 testing

The Departments of Labor, Health and Human Services, and the Treasury  issued a set of FAQson health plans’ coverage of OTC COVID-19 tests in view of President Biden’s actions and ACA, FFCRA, and CARES Act requirements. In general, health plans and issuers must cover the cost of or reimburse participants for OTC rapid COVID-19 tests.

  • Test purchases must be covered without the need for an order from a health care provider, a clinical assessment, or other pre-authorization.
  • The cost of the test must be covered without cost sharing, i.e. without deductibles, co-pays, etc.
  • The coverage requirement applies to the cost of test kits for individual diagnosis testing and not to routine testing for employment purposes.
  • The plan may set limits on the number or frequency of covered tests but must allow up to 8 tests per person per 30-day period or calendar month. For example, a family of four on the same plan could potentially get up to 32 covered tests per month. However, the plan may not set limits on the number of covered tests ordered by a health care provider following a clinical assessment.

Guidelines are effective January 15, 2022, but plans may provide no-cost OTC COVID-19 testing before that date.

Note: Individuals cannot use health FSA or HSA funds to pay for or reimburse themselves for OTC COVID-19 test kits provided at no charge.

Getting a no-cost test kit

CMS has also issued a set of FAQs detailing where and how they can get at home OTC test kits for free.  Participants should find out from their health plan provider whether their plan pays preferred pharmacies directly or they need to apply for reimbursement. If the plan has a preferred network of pharmacies and retailers, the plan can limit reimbursement for out-of-network tests to the smaller of $12 dollars per test or the cost of the test.

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