CMS Toolkit on COVID-19 Vaccine: Health Insurance Issuers and Medicare Advantage Plans (Apr. 6, 2022)
CMS has updated its COVID-19 vaccine toolkit to describe the COVID-19 vaccines and boosters currently authorized or approved by the Food and Drug Administration (FDA). Non-grandfathered group health plans must cover without cost-sharing any vaccine authorized under an Emergency Use Authorization (EUA) or approved under a Biologics License Application (BLA) by the FDA immediately upon the vaccine becoming authorized or approved (see our Checkpoint article). Coverage must be consistent with the scope of the EUA or BLA for the particular vaccine, including amendments allowing for the administration of an additional dose to certain individuals, administration of booster doses, or the expansion of the age demographic for whom the vaccine is authorized or approved. The updated toolkit now provides a detailed chronology of the EUAs and other approvals for the COVID-19 vaccines and boosters that have been approved for use in the United States.
EBIA Comment: While the toolkit is primarily intended for health insurers, its explanation of mandated vaccine coverage applies equally to self-insured health plans, and the listing of vaccines and boosters that must be covered without cost-sharing may be useful to plan sponsors. For more information, see EBIA’s Group Health Plan Mandates manual at Section XVI.C “COVID-19: Mandated Coverage of Diagnostic and Preventive Services”) and EBIA’s Self-Insured Health Plans manual at Section XIII.C.11 (“Coverage Mandates Relating to the COVID-19 Pandemic”).
Contributing Editors: EBIA Staff.