The Coronavirus Aid, Relief and Economic Security (CARES) Act requires non-grandfathered group health plans to cover qualifying COVID-19 preventive services, including COVID-19 immunizations, without cost sharing. A final rule was issued to implement this requirement and mandate coverage within 15 business days after approval by the Advisory Committee on Immunization Practices of the CDC and adoption by the Director of the Centers for Disease Control and Prevention.

This coverage must be provided for both in-network and out-of-network providers during the COVID-19 public health emergency.

Employers that are considering whether to encourage or require employees to get a COVID-19 vaccine can look to guidance related to the influenza vaccine, including OSHA and the EEOC’s ADA and Title VII limitations, since COVID-19 specific guidance has not been issued at this time. Additionally, employers should consult legal counsel to determine whether there are unique risks to consider for their specific organization.

Please see our bulletins below for additional information on the vaccination coverage mandate and employer considerations for whether to require vaccination.

Guidance on Coverage Requirements

Considerations Regarding COVID-19 Vaccine

Please contact our Employee Benefits team if you have questions or need assistance.