On Nov. 6, 2020, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) published an interim final rule requiring Medicare, Medicaid and private insurers to cover a COVID-19 vaccine without any cost-sharing, once the Food and Drug Administration (FDA) authorizes and approves a vaccine.
COVID-19 Vaccine Coverage for Private Health Plans
The interim final rule implements the requirement in the Coronavirus Aid, Relief and Economic Security (CARES) Act that non-grandfathered group health plans and health insurance issuers offering non-grandfathered group or individual health insurance coverage provide coverage, without cost-sharing, for qualifying COVID-19 preventive services, which includes COVID-19 immunizations.
The rule shortens the period of time in which coverage of qualifying COVID-19 preventive services is required. This coverage must be provided within 15 business days after the recommendation relating to a qualifying COVID-19 preventive service is made. Coverage of recommended COVID-19 immunizations must be provided, even if not listed for routine use on the Immunization Schedules of the Centers for Disease Control and Prevention (CDC).
In addition, during the COVID-19 public health emergency, plans and issuers must cover qualifying COVID-19 preventive services without cost-sharing, regardless of whether an in-network or out-of-network provider delivers the services. Plans and issuers subject to Section 2713 of the Public Health Service Act must also cover, without cost-sharing, items and services that are integral to the furnishing of recommended preventive services, including the administration of COVID-19 immunizations.
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