Over-the-Counter COVID-19 Testing: Insurance Coverage Strategies to Support Equitable Access

Executive Summary

Systematic, predictable, and equitable access to Covid-19 testing is essential for both successfully treating patients at risk of severe disease and slowing spread. At-home over the-counter (OTC) tests are reliable tools for individuals to quickly and conveniently detect Covid-19, but their cost can be a deterrent to appropriate early testing. Starting January 15, 2022, the Biden Administration required private insurance plans to cover the full cost of eight OTC Covid-19 tests per enrollee per month for the duration of the Covid-19 Public Health Emergency (PHE). Medicare beneficiaries received similar coverage beginning in early April. This coverage of Covid-19 OTC tests could increase access to testing and help to break chains of transmission and reduce the spread of the virus, especially with the emergence of new variants, such as the Omicron BA.2 subvariant, that appear to be more infectious. The individual health benefits of timely, no-cost access to OTC tests could be especially important for individuals experiencing elevated risk of severe illness and mortality from Covid-19, including Medicare and Medicaid beneficiaries, as they could seek treatment sooner when current therapeutics are more effective.

However, especially with the Covid-19 PHE potentially coming to an end later this year, there is no clear or widely accepted understanding of policies for how rapid OTC tests fit into the nation’s longer-term strategy for controlling Covid-19. Health plans generally have not covered OTC tests, especially when used for surveillance and screening rather than diagnosis to facilitate treatment. President Biden’s recent proposal for federal purchasing of tests raises questions about how new federal initiatives will complement or replace current coverage requirements, both during the Covid-19 PHE and potentially beyond it, when future Covid-19 cases and surges may still occur. With more widespread availability of effective oral and intravenous treatments, reliable and broad availability of timely Test to Treat care pathways for people at elevated risk of severe Covid-19 complications will be a key element in preventing future infections from translating into serious complications and health system impacts. There is potential bipartisan agreement on additional funding for the procurement of tests, treatments, and vaccines for some period beyond the PHE, but no agreement on funding for mechanisms to distribute the tests. Especially if Congress does not authorize broad ongoing funding for federal test purchases, and for widespread availability of Test to Treat capabilities through public health delivery sites, insurance coverage could be an important avenue for reliable access to tests and Test to Treat pathways. If federal and state governments plan to depend on continued insurance coverage of tests outside of the PHE, it will be necessary to develop guidance around coverage requirements, longer-term affordable access strategies, and educational plans on when to use these tests and how to understand and act on the results. Under the insurance coverage approach, important gaps in access to testing would remain for people who are uninsured as well as for any insured individuals who face unaffordable upfront costs for testing or treatment. With the growing availability of rapid diagnostic tests as well as effective but underused treatments for a range of infectious and chronic diseases, these issues of optimal insurance coverage related to rapid diagnostics and treatment pathways will arise in an increasing number of disease contexts in the future.

Read more