COVID vaccine vialFor now, the federal government is picking up the cost of the vaccine itself; however, vaccination providers will be able to charge an "administration fee" for giving the shot to someone.

With COVID-19 vaccination access ramping up across the United States, group health plan sponsors should carefully consider the new coverage requirements mandated for these vaccines. Specifically, Congress directs group health plans to cover COVID-19 vaccines under the familiar framework of the Affordable Care Act's (ACA) preventive services rule. This article offers a brief overview of compliance obligations affecting group health plans' coverage of COVID-19 preventive services (specifically the vaccine) as well as other important employer concerns.

COVID-19 vaccine coverage mandate

Today's vaccine coverage rules harken back to the original twin Coronavirus relief measures enacted almost a year ago. When Congress enacted the Families First Coronavirus Response Act (FFCRA) and Coronavirus Aid, Relief and Economic Security Act (CARES), the media prominently highlighted the provision directing group health plans to cover COVID-19 testing at no cost to plan participants. Although drawing comparatively less attention at the time, legislators anticipated eventual vaccine availability and therefore included CARES Act language that now mandates COVID-19 vaccine(s) coverage without cost-sharing.

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