Q: Must employer sponsored health plans cover a vaccine for COVID-19 when it becomes available?
A: Yes. Under the CARES Act, all health plans, whether private, governmental or church plans are required to cover U.S.-government approved measures to prevent COVID-19, including vaccines, without cost sharing. This applies to all types of group health plans as well, including PPO, HMO, high deductible health plans, and even minimum essential coverage plans.
Per guidance issued in October 2021, a new vaccine or other biologic must be covered immediately once it receives an “Emergency Use Authorization” by the FDA or “Biologics License Application” by the FDA. In other words, as soon as the FDA authorizes booster shots, additional age groups, or other changes, plans must cover the vaccines and their administration immediately.
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