The Internal Revenue Service (IRS) published IRS Notice 2023-37 on June 23, 2023, which revokes the existing COVID-19 relief that allows HDHPs to provide first dollar coverage for COVID-19 testing and treatment without affecting the ability to contribute to HSAs. This will affect calendar and non-calendar year HDHPs at different times.
This Alert addresses the existing relief and its expiration, and it is applicable to any employer sponsoring an HDHP providing coverage for COVID-19 testing and treatment that bypasses the deductible.
