The Impact of Expanding Pre-Deductible Coverage in HSA-Eligible Health Plans on Use of Health Care Services

Summary

IRS Notice 2019-45 allows health savings account (HSA)-eligible health plans the flexibility to cover 14 medications and other health services used to prevent the exacerbation of chronic conditions prior to meeting the plan deductible. In this Issue Brief, we use claims data to quantify the effect of expanding pre-deductible coverage on use of health care services.

Key Findings:

• Overall, we found that between 2018 and 2021, the IRS notice increased the use of 3 of the 7 medical services by more in HSA-eligible plans compared with non-HSA-eligible plans. Use of low-density lipoprotein (LDL) testing, hemoglobin A1C (HbA1C) testing, and retinopathy screening increased by a larger percentage among enrollees in HSA-eligible plans compared with those health plans not targeted by this policy change, suggesting that the IRS contributed to increased use of these services.

   

• In addition, use of selective serotonin reuptake inhibitors (SSRIs), statins, and angiotensin-converting enzyme (ACE) inhibitors increased by a larger percentage among enrollees in HSA-eligible plans compared with those health plans not targeted by this policy change, suggesting that the IRS also contributed to increased use of these prescription drugs.

Use of health services may not have changed for all targeted services and prescription drugs because many employers substituted copayments and/or coinsurance for deductibles. Past EBRI research found that the percentage of employers that eliminated cost sharing for the preventive services identified in the IRS notice ranged from a low of 25 percent to a high of 40 percent depending on the service examined. In other words, 59 percent to 75 percent of employers substituted either copayments or coinsurance for the deductible, depending on the service or drug.

Employers would exclude additional preventive services if allowed by the IRS, according to past EBRI research. If employers’ goal is to increase use of those services, they should consider their approach to cost sharing.