2024 IRS HDHP Notices: The Impact on Pharmacy

Change for high deductible health plans (HDHPs) will impact pharmacies and the patients they serve. | Viewpoints

by Patricia Milazzo, R.Ph.

Several changes are on the way for high deductible health plans (HDHPs) that will impact pharmacies and the patients they serve. On Oct. 17, 2024, the IRS issued two notices.

Read on to Learn More about The 2024 IRS HDHP Notices:

• The Products and Services Impacted by 2024 IRS HDHP Notices.

• What Do The 2024 IRS HDHP Notices Mean for Pharmacy?

• A Clinical Opportunity for Pharmacies Arising from The 2024 HDHP Notices.

1. The first provides clarification of IRS Notice 2019-45, which previously allowed coverage on a pre-deductible basis for specific preventive products and services for HSA-compatible HDHPs. The 2024 notice also allows the cost of condoms to be treated as Code Section 213(d) Eligible Medical Expenses. In most cases, under the rules for HSAs, an HDHP may not pay benefits until its deductible has been satisfied. In one exception to the general rule, expenses for “preventive care” may be paid before the deductible has been reached.

1. Another notice, Notice 2024-75, is entitled “Preventive Care for Purposes of Qualifying as a High Deductible Health Plan under Section 223.” Notice 2024-75 clarifies the list of preventative care benefits that an HDHP can provide coverage for on a pre-deductible basis. At first glance, the ruling appears to primarily impact prescription drug plan administrators. A closer reading of the IRS publication reveals changes that may impact pharmacies.