On June 27, 2019, President Trump issued an executive order directing federal agencies to issue guidance in several areas. In response, the Internal Revenue Service (IRS) has released Notice 2019-45, expanding the usability of High Deductible Health Plans (HDHPs). Under this notice, specific medical care services and items, including prescription drugs, should be classified as preventive care under the HDHP rules, if they are being prescribed for chronic conditions. Thus, these specified treatments and prescription drugs are permitted to be covered without the deductible being applied. This “Compliance Bulletin” provides a list of the medical diagnoses and related treatments that are impacted by Notice 2019-45. Many insurance carriers, pharmacy benefit managers and third party administrators may already offer some of these services and prescription drugs classified as preventive according to the Affordable Care Act (ACA), and therefore are processing them without regards to the deductible. Employers should, however, work with their employee benefits consultant and claims administrator to determine if any plan design or cost adjustments need to be made to their health plans as a result of this latest IRS Notice.
Changes in the healthcare arena continue to occur and your Cowden consultant is available to help you with legislative changes to your plan.
Contact your Cowden representative for more information on this or other compliance issues.