On December 16, 2020, the Department of Financial Services (DFS) issued Circular Letter No. 16 to insurers authorized to write accident and health insurance in the state, among other entities. The purpose is to provide guidance related to coverage of COVID-19 immunizations and their administration.
The letter explains the state insurance law requirements for coverage of immunizations without cost sharing under health insurance policies and contracts. Additionally, the federal coverage requirements under the CARES Act are explained. The CARES Act requires issuers to cover recommended COVID-19 immunizations and their administration at no cost sharing under all non-grandfathered group and individual comprehensive health insurance policies and contracts. For the duration of the COVID-19 public health emergency, the coverage extends to COVID-19 immunizations by out-of-network providers, who must be reimbursed at a reasonable rate.
Coverage under the CARES Act is required within 15 business days after the immunization has been recommended by the Advisory Committee on Immunization Practices (ACIP). However, the letter states that given the need for urgency, issuers should cover any COVID-19 immunization immediately upon ACIP’s recommendation rather than wait 15 business days.
Accordingly, issuers are advised to take the necessary measures to ensure that insureds have access to coverage for COVID-19 immunizations and their administration without cost sharing and are provided with the necessary information to access it. In addition, issuers are advised to provide information to providers regarding submission of reimbursement claims and to remind providers that they are prohibited from balance-billing insureds. Issuers are also required to provide DFS with the name and contact information of the person responsible for communicating with DFS regarding implementation of COVID-19 immunization coverage.
Although the letter is directed at insurers, employers may want to be aware of this communication.
Circular Letter No. 16 »
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