December 10, 2020
In an interim final rule released in November of 2020, the Department of Health and Human Services, Department of Labor, and Internal Revenue Service (Departments) detailed rules governing coverage of the anticipated COVID-19 vaccine(s). These rules apply to all employer-sponsored group health plans, insured and self-insured. Specifically, group health plans must:
- Cover all vaccine doses without cost-sharing (no copays, coinsurance, deductibles);
- Cover all services integral to furnishing the vaccine such as specimen collection; and
- Cover the vaccines whether administered in- or out-of-network—at a negotiated rate, or at prevailing market rates.
Employer-sponsored group health plans must cover the vaccine(s), without cost-sharing, within 15 business days after the vaccine is recommended by the Advisory Committee on Immunization Practices (ACIP) and the Centers for Disease Control and Prevention (CDC).
The Departments will accept comments on the interim final rule until January 4, 2021. We welcome input and questions from all Business Group members for submission to the Departments. We expect that the Departments will issue additional guidance, and we’ll update members when that guidance becomes available.
Additional details and discussion of the interim final rule are available in our prior Regulatory & Compliance Update.
If you have questions, comments, or concerns about these or other regulatory and compliance issues, please contact us.
We provide this material for informational purposes only; it is not a substitute for legal advice.