March 02, 2021

On February 28, 2021, the Advisory Committee on Immunization Practices (ACIP), responsible for recommendations on US adult and childhood immunizations, voted to recommend the Johnson & Johnson COVID-19 vaccine (also referred to as the Janssen vaccine) for persons age 18 and older under the Food and Drug Administration’s (FDA’s) Emergency Use Authorization. This makes the Johnson & Johnson’s the third authorized and recommended COVID-19 vaccine, after the Pfizer-BioNTech and Moderna vaccines.

Under the CARES Act and implementing regulations, all group health plans—insured and self-insured—are required to cover ACIP recommended vaccines with no cost-sharing (no copays, coinsurance, deductibles). The ACIP meeting materials include more details on the Johnson & Johnson vaccine.

Effective Date

Employer-sponsored group health plans must cover the Johnson & Johnson vaccine, without cost-sharing, within 15 business days after ACIP’s and the Centers for Disease Control and Prevention’s recommendation. Therefore, we recommend that group health plans be prepared to cover the Johnson & Johnson COVID-19 vaccine by March 19, 2021.

What's Next?

We will provide a more detailed discussion of this and other new COVID-19 guidance in our next regulatory and compliance webinar on March 18, 2021 at 12:00PM ET. Members can register here.

We expect that in the coming weeks and months, the FDA and ACIP may authorize and recommend additional COVID-19 vaccines that group health plans must then cover without cost-sharing. Federal agencies may issue more guidance on COVID-19 vaccine coverage. We will keep our members updated of any new recommendations, guidance, and effective dates.

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.

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