Since Jan. 15, 2022, employer health plans and individual health insurance issuers have been required to cover at-home COVID-19 tests purchased over the counter for the duration of the coronavirus public-health emergency. The resulting costs to health plans for covering these tests could represent a significant unanticipated expenditure in 2022 and beyond. In this paper, we provide two estimates of the potential costs of a fully compliant direct coverage pathway in 2022 to address the variability in costs associated with factors such as:

• Infection rates
• Local and workplace testing requirements
• Federal efforts for free testing
• Compliance requirements