Coverage of COVID-19 Vaccines: Agencies Issue Interim Final Regulations
As part of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) signed into law in March 2020, most group health plans are required to provide no-cost coverage for COVID-19 preventive services, including vaccinations. On November 6, the Internal Revenue Service, the Department of Labor, and the Department of Health and Human Services (the Agencies) released interim final regulations to address the details of how plans should provide this coverage.
Mandated Coverage
Under the Affordable Care Act, non-grandfathered health plans are required to cover qualifying preventive care services without cost-sharing. Plans are given one year from the date that recommendation is made by the Centers for Disease Control and Prevention (CDC) to implement newly recommended services.
The CARES Act builds upon this existing requirement by specifically requiring plans to provide no-cost coverage for any item, service, or vaccination intended to prevent or mitigate COVID-19. Importantly, the CARES Act shortens the timeframe within which a plan must implement this coverage from one year to 15 days following CDC’s recommendation.
Plans must cover the full cost of the vaccine, including administration, whether it is provided by an in-network or out-of-network provider. Cost-sharing may not be imposed on office visits if the primary purpose of the visit is the administration of the vaccine. This coverage mandate is in effect until the end of the public health emergency period.
Employer Action Items
While a COVID-19 vaccine has not yet been made publicly available, plan sponsors should act now to prepare to provide the mandated coverage within 15 days following CDC recommendation.
For sponsors of a fully-insured health plan, the health insurance carrier will be required to take the necessary steps to provide this no-cost coverage. However, sponsors of a self-insured health plan will need to proactively coordinate with the claims administrator or TPA, as well as the stop-loss carrier, to ensure procedures are in place to properly review and pay claims for these benefits. Though grandfathered health plans are not subject to these coverage requirements, the Agencies make clear that they are nevertheless encouraged to follow them.
Finally, all sponsors of health plans, regardless of insured status, will need to review existing Plan Documents and Summary Plan Descriptions to confirm that the materials accurately describe the coverage for COVID-19 vaccinations. A Summary of Material Modification (SMM) may be necessary.
Additional Resources
Contact an Acrisure Agency Partner to learn more.
Important Information:
For additional information, please visit our website at Acrisure.com. Products or services identified herein may not be available in all jurisdictions. The information and descriptions contained herein (a) are not necessarily intended to be complete descriptions of all applicable terms, conditions, and exclusions of the policies referenced, (b) are provided solely for general informational purposes, and (c) should not be viewed as a substitute for legal, regulatory, or other advice on any particular issue or for any particular reason. The advice of a professional should always be obtained before purchasing any insurance product or service, and you should not rely on the information provided herein for the prevention or mitigation of risks or as a full and complete explanation of coverage under any insurance policy. While the information contained herein has been compiled from sources believed to be reliable, no warranty, guarantee, or representation, either expressed or implied, is made as to the correctness or sufficiency of any representation contained herein.
© Acrisure, LLC. All rights reserved.
This Benefits Bulletin is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.
Related Content
January 26, 2021
Attend the Virtual HR Leaders Compliance Summit: Feb 9 – 11
The HR landscape isn’t getting any simpler, especially for leaders. Join Acrisure and its Agency Partners for a virtual summit dedicated to the most pressing topics facing HR leaders today.
January 19, 2021
Acrisure Agency Partner Named One of Insurance Journal’s ‘2020 Agents of the Year’
Insurance Journal's report "features 25 agents who define what it means to be a successful independent agent today. These agents are more than top sellers.
January 13, 2021
5 Steps for Year-Round Benefits Engagement
Open enrollment is something you probably only think about a few times a year. For employees, it might be even less often. And that’s unfortunate because that means employees may not be maximizing their benefits. That’s why it’s important to touch on benefits throughout the year—to ensure employees are making the most of them.
January 4, 2021
New COVID-19 Relief Bill: Highlights for Employers
On December 27, 2020, President Trump signed into law the much-anticipated COVID-19 relief bill (the “Bill”), which was approved by Congress a week earlier. The Bill, a follow-up to the March 2020 CARES Act, provides a second round of stimulus dollars and economic relief measures; it also contains several provisions of particular importance to employers.
December 23, 2020
What We Know So Far: Understanding the $900B Stimulus Package
On Monday, Dec. 21, 2020, Congress passed an emergency stimulus package designed to deliver approximately $900 billion in COVID-19-related aid. The bill, which was part of a $1.4 trillion spending package that will keep the government open for the fiscal year, has been sent to President Donald Trump, and he is expected to sign it into law.
December 8, 2020
Acrisure Unveils New Tech-Enabled Brand
Acrisure, one of the world’s top-10 insurance brokers, today unveiled its new brand identity which underlines its unique combination of financial strength, industry expertise and global distribution power with the integration and deployment of best-in-class artificial intelligence and technology.
December 2, 2020
Benefits Update: December 2020
The Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) issued a final rule that imposes new transparency requirements on group health plans and health insurers in the individual and group markets.
November 19, 2020
Study Finds That Workers’ Compensation Mega Claims Are on the Rise
While any workers’ compensation claims can result in costly ramifications for your organization, one category of claim in particular—known as a “mega claim”—has the potential to carry significant consequences.
November 3, 2020
Acrisure Perspective: 6+ Million Households & Property Owners Could Be Underestimating Their Flood Risk
According to the insurance professionals at Acrisure’s Agency Partners, we believe that this disparity points to a worrisome trend: more than 6 million households and property owners could be underestimating or unaware of the extent of their flood risks.
October 27, 2020
Success Tips: Performance Reviews With Remote Employees
Performance reviews are traditionally conducted in-person, on a recurring basis. But, amid the COVID-19 pandemic, most businesses have at least some employees working remotely.