The one-year mark of COVID-19’s vice grip on the United States is fast approaching. While this past year has been marked by hardship and uncertainty, the recently approved vaccines give hope to many. With the arrival of the vaccine and the beginning of distribution efforts well underway, many are still only cautiously optimistic. How will we approach distribution of the vaccine? What are the requirements for employers? What is the relationship between the COVID-19 vaccine and fully insured plans?
We’re here to answer some of those questions.
What You Need to Know About The COVID-19 Vaccine
Let’s begin with a quick refresher on the proposed timeline for the vaccine’s rollout. The Federal Drug Administration (FDA) has approved, for emergency use, both the Pfizer/BioNTech and Moderna COVID-19 vaccines. Shortly thereafter, the CDC’s Advisory Committee on Immunization Practices recommended the use of these vaccines. The federal government is currently overseeing the initial distribution of these vaccines across each state developing its own plans for distribution. As of now, distribution of the vaccine is being carried out in phases based on priority groups. The FDA will meet on February 26th to determine whether the Johnson & Johnson vaccine will also be approved for emergency use and included in the nation-wide distribution. What does this mean for insured group health plans?
Reception of the vaccine has been varied, from positive enthusiasm to skepticism or outright rejection. The CDC has introduced “Vaccinate with Confidence” as a strategic framework to address community and personal concerns, provide current information on all immunization efforts, and to combat rampant misinformation associated with vaccines.
Employer Requirements and Resources for the COVID-19 Vaccine
The CARES Act requires that health insurance providers and group health plans cover CDC-recommended COVID-19 vaccines as preventative care with no member cost sharing within 15 days of a CDC recommendation. Under Operation Warp Speed, the federal government paid for the vaccine serum itself, at least for the initial inoculation of US consumers, but health insurance plans will likely be required to cover the costs related to administering the vaccine.
For fully insured medical plans, this means that neither the participant nor the employer will incur any costs related to the vaccine, so long as the vaccine administration is run though the benefit plan. If an employer wants to coordinate a “vaccine drive” for plan participants at their workplace this would also need to be coordinated with the carrier. It is worth noting that fixed indemnity plans (ACA Excepted Benefits) may not cover the cost of the vaccine in the same manner as other plans. Indemnity plans will pay the scheduled fixed benefit amount for services and prescriptions related to administering the vaccine, and any potential patient responsibility will depend on the plan guidelines.
It is already a requirement under the Affordable Care Act for group health plans and insurers to cover preventative care items with no cost-sharing. Due to the ongoing pandemic the CARES Act modified the preventative service rules for the COVID-19 vaccine, requiring group health plans to provide first-dollar coverage of COVID-19 vaccines.
The COVID-19 Vaccine as One Part of a Larger Solution
The COVID-19 vaccine is a hopeful bearer of a gradual return to normalcy. Even as the vaccine slowly rolls out, vigilance and common sense are still crucial. Employers must continue to promote all best practices and precautions to protect their workforce from COVID-19. Social distancing, masks, and mindful hygiene are still our greatest weapons against the coronavirus. Many health experts continue to weigh in on the effectiveness of masks and urge the public to continue to wear them for the foreseeable future.
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