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Remember: Group Health Plans Must Cover the Cost of COVID-19 Vaccinations for Participants


In light of the fact that it appears that a COVID-19 vaccine will soon be available, it is worth a reminder that the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act requires all employer sponsored group health plans, whether fully insured or self-insured, to pay the full cost of the COVID-19 vaccine for employees covered under the company’s group health plan with no offset by co-payments, deductibles or co-insurance. The prevention from cost sharing includes services necessary to administer the vaccine, such as office visits, even if the services are separately billed.  

The CARES Act coverage requirement becomes effective within fifteen (15) days of the vaccine being recommended by the Centers for Disease Control and Prevention’s Advisory Committee on Immunization Practices (“ACIP”). This is a special rule for COVID-19. Normally, there is a one (1) year waiting period between the time the ACIP makes a recommendation and when a group health plan is required to cover the preventative service. Therefore, Plan sponsors need to be vigilant and make sure that their group health plans are being administered properly, and prepare any necessary amendments to make sure that the cost of these vaccines are fully subsidized by the plan for participants.

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