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These resources – like the public health crisis itself – are constantly evolving and are only current as to the date of publication. This page was last updated on April 26, 2020.

We recommend that you monitor this site, as well as the sites referenced in these resources, for updates and changes as we expect the situation and solutions to change over the coming weeks and months. For information on specific programs, we encourage you to visit the websites of the organizations or government entities that are responsible for the relief.

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Description of Program and Relief

CARES Act: Coverage of Testing and Preventative Services

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) mandates that private health insurers cover certain testing and preventative services for COVID-19 without prior authorization and at no cost.

  • No-cost Testing. The CARES Act extends no-cost testing requirements beyond FDA-approved tests for COVID-19 to include:

  • (1) tests for which the developer has or intends to request emergency use authorization;

  • (2) state-developed labs; and

  • (3) any other test that the Secretary of Human Health and Services determines appropriate for COVID-19 in guidance.

Coverage of these categories of testing is not subject to any deductible, co-pay, or requirement for pre-authorization.

  • No-cost Preventative Services. Private health plans must also cover, at no cost, any “qualifying coronavirus preventive service,” defined as any item, service or immunization to prevent or mitigate coronavirus. “Qualifying services” include:

  • (1) an item or service that is evidence-based and rated A or B under a U.S. Preventative Services Task Force recommendation; or

  • (2) any immunization recommended by the U.S. Centers for Disease Control and Prevention for the individual involved.

Government or Lead Agency

Department of Health and Human Services.

Dates Available

No cost-testing under this Title begins March 27, 2020 throughout any portion of the public health emergency declared by the Secretary of Health and Human Services.

Coverage for immunizations will begin 15 business days after the date on which an applicable recommendation of an item, service, or immunization is issued.

Eligibility Requirements/Restrictions

While the Families First Coronavirus Response Act covers no-cost testing for both public and private insurance beneficiaries, the expanded no-cost testing requirements under the CARES Act (e.g. the expansion of testing by clinical labs and state developed labs) do not extend to individuals covered by public health programs such as Medicare, Medicaid, the Children’s Health Insurance Program, veterans coverage or Indian Health Services, or the uninsured.


© 2021 Paul, Weiss, Rifkind, Wharton & Garrison LLP. This does not constitute legal advice and does not create an attorney-client relationship. In some jurisdictions, this publication may be considered attorney advertising. Past representations are no guarantee of future outcomes.

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