Further Guidance Published on Coverage of COVID-19 Tests and Vaccines

The Departments of Labor, Health and Human Services, and Treasury have jointly released a new round of FAQs addressing questions related to the coverage of COVID-19 diagnostic testing and vaccines. As a reminder, both grandfathered and non-grandfathered health plans are required to cover diagnostic testing at no cost to the participant, while non-grandfathered health plans are required to cover the vaccine and its administration at no cost to the participant. Significant clarifications from the FAQs are outlined below.

The guidance clarifies that health plans may not impose medical management techniques, including medical screening criteria, on coverage of COVID-19 diagnostic testing. For example,

plans may not deny or impose cost sharing on a diagnostic test for an asymptomatic participant who has no known or suspected exposure to COVID-19. The FAQ emphasizes that determining the appropriateness of a diagnostic test falls on the participant’s health care provider and public health authorities, not health plans. It also clarifies that diagnostic testing must be covered if provided at state- or locality-administered testing sites.

Currently, many vaccines require two doses and the FAQs note that a non-grandfathered plan must cover the cost of multiple doses as necessary to be considered a complete vaccination. Additionally, plans must cover the cost of the administration of the vaccine, even if the vaccine itself is not billed to the plan. Finally, a plan may not deny coverage of the vaccine because a participant does not qualify for a vaccine under the current state or local government criteria for priority vaccination.