The Departments of Health & Human Services, Labor, and Treasury (collectively, the “tri-agencies”) published guidance on April 11 in attempt to clarify some of the testing coverage requirements under FFCRA and the CARES Act. However, as calls have increased for more widespread and frequent testing, particularly of at-risk populations such as health care workers, residents and staff of long-term care facilities, and people potentially exposed at protests or rallies, insurers have questioned their responsibility to cover all testing in all circumstances.On June 23, the tri-agencies published new guidance that attempts to answer implementation questions from states, plans, and insurers, including the definition of “medically necessary”, surveillance or workplace related testing, coverage of hospital “facility fees”, and protections against provider balance billing.