Council Foundation Logo Leaders Edge

March 1, 2021

On February 26, 2021, the Center for Medicare and Medicaid Services (CMS) issued additional guidance regarding coverage of COVID-19 vaccines and testing for group health plans (including self-insured plans), health insurance issuers offering group or individual health insurance coverage, and providers of COVID-19 related services to the uninsured.

Updated guidance includes:


  • Plans and issuers must cover all COVID-19 vaccines without cost sharing for all vaccines that have received a recommendation from the Advisory Committee on Immunization Practices (ACIP). Plans and issuers are not permitted to exclude coverage for (or impose cost sharing on) any qualifying coronavirus preventive services.
  • Plans and issuers must cover the vaccine administration fee without cost sharing for an immunization, regardless of how the administration is billed, and regardless of whether a COVID-19 vaccine or any other immunization requires the administration of multiple doses in order to be considered a complete vaccination. This includes covering without cost sharing the administration of a required preventive immunization in instances where a third party, such as the Federal Government, pays for the preventive immunization.
  •  A plan or issuer may not deny coverage of recommended COVID-19 vaccines because a participant, beneficiary, or enrollee is not in a category recommended for early vaccination.


  • Plans and issuers must cover qualifying coronavirus preventive services without cost sharing starting no later than 15 business days (not including weekends or holidays) after the date the United States Preventive Services Task Force (USPSTF) or ACIP makes an applicable recommendation regarding a qualifying coronavirus preventive service. The requirement to cover the Pfizer BioNTech COVID-19 vaccine became effective January 5, 2021, and the requirement to cover the Moderna COVID-19 vaccine became effective January 12, 2021.


View the full FAQ document prepared by the Departments of Labor, Health and Human Services (HHS), and the Treasury.