Additional Guidance Addressing COVID-19 Vaccines

On January 21, 2021, Commissioner Anderson issued Bulletin 2021-01, providing updated guidance reminding carriers that they should facilitate members’ access to COVID-19. This bulletin adds additional carrier expectations to those that were expressed in Bulletin 2020-32 (which was discussed in the January 7, 2021, edition of Compliance Corner).

This bulletin clarifies that the Division of Insurance expects carriers to:

• Forgo any cost sharing for vaccinations at providers’ offices (including from out-of-network providers
• Reimburse providers (whether in-network or out-of-network) for the cost of administering COVID-19 vaccines at a level that is higher than the MassHealth rate of reimbursement
• Reimburse providers for the vaccine separately if it is administered and billed separately from the full office or emergency visit
• Pay all subrogation claims for any vaccines administered at pop-up locations, mass vaccination sites, or public clinics hosted by state or municipal health departments

The division also encourages carriers that are acting as administrators to self-insured plans to follow this guidance as well.

Although this bulletin is directed towards insurance carriers, employers based in Massachusetts should familiarize themselves with this guidance as they continue to contend with participants being affected by COVID-19.

Bulletin 2021-01 »