IRS Allows High Deductible Health Plans to Provide Pre-Deductible Benefits for Chronic Care Management
Earlier this week, the Internal Revenue Service (“IRS”) issued guidance expanding the list of “preventive care benefits” that a high deductible health plan (“HDHP”) may cover before a participant has met the plan’s deductible. Preventive care benefits now include the following services and items when prescribed to treat the specified chronic conditions:
| Preventive Care for Specified Conditions | For Individuals Diagnosed with |
| Angiotensin Converting Enzyme (ACE) inhibitors | Congestive heart failure, diabetes, and/or coronary artery disease |
| Anti-resorptive therapy | Osteoporosis and/or osteopenia |
| Beta-blockers | Congestive heart failure and/or coronary artery disease |
| Blood pressure monitor | Hypertension |
| Inhaled corticosteroids | Asthma |
| Insulin and other glucose lowering agents | Diabetes |
| Retinopathy screening | Diabetes |
| Peak flow meter | Asthma |
| Glucometer | Diabetes |
| Hemoglobin A1c testing | Diabetes |
| International Normalized Ratio (INR) testing | Liver disease and/or bleeding disorders |
| Low-density Lipoprotein (LDL) testing | Heart disease |
| Selective Serotonin Reuptake Inhibitors (SSRIs) | Depression |
| Statins | Heart disease and/or diabetes |
The guidance allows HDHPs to cover any or all of the expanded list of preventive care benefits pre-deductible, without negatively impacting a participant’s ability to contribute to a health savings account. Employers may amend their HDHPs immediately to account for the changes or incorporate the changes as of the start of the next plan year.
Significantly, the IRS guidance does not alter the definition of "preventive care benefits" for purposes of the Affordable Care Act’s requirement that a group health plan cover certain preventive care benefits without cost sharing. This means that an employer may choose to amend its HDHP to cover the newly designated preventive care benefits pre-deductible, but is not required to make these changes and may still subject such benefits to copays or coinsurance.
For more information about this new IRS guidance, please contact your Executive Compensation and Employee Benefits Counsel at Smith, Gambrell & Russell, LLP.
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