Figure 1 Cost-Sharing Arrangement as a Result of IRS Rule 2019-45 Conclusion Statins 40% 48% 11% Anti-Resorptive Therapy 40% 54% 6% In response to IRS Notice 2019-45, some employers added pre-deductible coverage with no cost sharing, while November 18, 2021, #413 Blood Pressure Monitor others required some form of cost sharing. While em 38% ployers could have also limited pr 57% e-deductible cove 4% rage to generic drugs, a majority covered brand-name drugs as well. It is clear that these employers are concerned about Low-Density Lipoprotein (LDL) Testing 36% 49% 15% preventing the exacerbation of chronic conditions. If patients avoid taking medications as a result of costs — Retinopathy Screening 36% 53% 11% whether they are generic or brand-name drugs — failing health could result in not only higher health care Employer Cost-Sharing Arrangements for spending overall, but lower produ Glucct omie vi terty as well. 36% 50% 14% Preventive Medications and Services in Hemoglobin A1C Testing 36% 56% 8% Peak Flow Meter 34% 55% 8% Response to Increased IRS Flexibility Data and Study Sample Beta Blockers 33% 59% 9% Recent research from the Employee Benefit Research Institute (EBRI) explored how employers approached cost The data for this study come from an online survey of benefits decision makers. A total of 354 large International Normalized Ratio (INR) Testing 30% 50% 19% sharing for medications and services that IRS Notice 2019-45 now allows health savings account (HSA)-eligible employers were surveyed, including 270 that made changes to pre-deductible coverage and 62 that did not. Insulin and Other Glucose Lowering Agents 30% 60% 11% health plans to cover. The research is based on findings from a 2021 EBRI survey of employers. Not all respondents answered every question. The survey averaged 10 minutes. The research was conducted in July and AugustIn o ha f 2021. led Cortic osteroids 26% 61% 13% Selective Serotonin Reuptake Inhibitors (SSRIs) 25% 63% 11% Angiotensin Converting Enzyme (ACE) Inhibitors 25% 59% 16% Abou IRS t EB Not RI: ice The E 2019 m- p45 loy ee Benefit Research Institute is a private, nonpartisan, nonprofit research institute 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% based in Washington, DC, that focuses on health, savings, retirement, and economic security issues. EBRI does Zero Cost to Employee Employee Pays Copay Employee Pays Coinsurance Some Other Amount not lThe U obby and do .S. Depa esr no tmten take t of pol Trea icy po sury i siss tio ue ns. Th d guie dan wor cek on of EB July 17, RI is 2019, v made pos ia I si R bS N le by f otic und e 2019 ing - f45 t romo f its m urth em er bers and s incr ponsor ease t s, whi he flch exiib nc ililtud y of e a h br eaoad lth sravi ang ne of gs a cc publ oun ic, t (p H riSA vat)e, -el fi og ri-b pr le h ofiea t and n lth plonpr ans tof o co it or ver gan spec izatiifo ic ns. Fo low-r cos mt or e Source: Employee Benefit Research Institute survey. 1 infor pr m eve ation g ntive o t se o rw viw ces w .eb to pr ri.or evg ent or t he conne exac cter w biat th ion o us on f ch Tw ro it ni ter c c oondi r LinkedI tions o n. n a p re-deductible basis. A Than With I k Y Rou S N tot o O ice ur Fu 2019n -der 45 i: n pl Tha is ce st , a ud lly w HSA as -condu eligibl ce he ted wi altth pl h the ans fund are ing s nowuppo able t rto a of dopt the N a at m iona ore lf lexible Between 57 percent and 69 percent provided pre-deductible coverage for both brand-name and generic drugs in Pharbene maceut fit des icali C gn o oun ffci erli. ng more protection for certain medical services through a value-based insurance design the specified drug classes. (V-BID) plan structure. ### Figure 2 Tiers of Drug Covered Pre-Deductible as a Result of IRS Rule 2019-45 It found that some employers added pre-deductible coverage with no cost sharing, while others required some Generics Only Generics & Brand Names form of cost sharing. In addition, whether cost sharing was added in lieu of a deductible varied across the 14 100% medications and services. Among the medications that could be covered on a pre-deductible basis, some employers covered both brand-name and generic drugs, while others covered only generic drugs. 90% 80% 57% 58% Key F 70 in %dings From the Survey 60% 61% 64% 69% 60% 50% The percentage of employers that eliminated cost sharing for various pre-deductible services ranged from a low of 25 percent to a high of 40 percent. Between nearly one-half and two-thirds required a copayment from employees, 40% depending on the health care service. 30% 42% 43% 20% 40% 39% 36% 31% 10% 0% Insulin and Other Selective Serotonin Beta Blockers Angiotensin Converting Statins Inhaled Corticosteroids Glucose Lowering Reuptake Inhibitors Enzyme (ACE) Agents (SSRIs) Inhibitors 1 https://www.irs.gov/pub/irs-drop/n-19-45.pdf Source: Employee Benefit Research Institute survey. EBRI’s on Twitter! @EBRI or http://twitter.com/EBRI EBRI blog: https://ebriorg.wordpress.com/ E EB BR RI I on on T Twitt witte er r: : @ @E EB BR RI I o or r htt http:/ p://t /twit witter ter..c com/ om/E EB BR RI I B Blog: log: htt https ps:/ ://ebr /ebrior iorg. g.wor wordp dpr re es ss s..c com/ om/ © 2021, Employee Benefit Research Institute, 901 D St. SW, Suite 802, Washington, DC 20024, 202/659-0670 www.ebri.org 2 3

