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Welcome to The Friedman Blog

New Rules Require Health Plans to Cover COVID-19 Vaccines, More

12/7/2020

 
New Rules Require Health Plans to Cover COVID-19 Vaccines
​The Trump administration has issued new interim final rules that set out accelerated coverage requirements for COVID-19 preventive services and covering out-of-network testing for the coronavirus.
​There are two parts to the interim final rules:  
  • One requires that COVID-19 preventive services - including vaccines - be covered without any cost-sharing on the part of plan enrollees.
  • The second creates a reimbursement formula for insurers to pay for COVID-19 testing conducted on their enrollees by out-of-network providers.

The new rules, which implement important parts of the CARES Act, were rolled out by the Treasury, Labor, and Health and Human Services departments.

If you are a plan sponsor, you need to know how this affects your group health plan so you can help your staff understand how testing and preventive COVID-19 services are covered.
 
COVID-19 preventive services
The CARES Act requires that COVID-19-related preventive services be covered within 15 business days after a doctor recommends that a patient needs them.

COVID-19 preventive services must be covered without any out-of-pocket costs on behalf of health plan enrollees, whether they receive those services inside or outside their plan's provider network. The reason for this is that as vaccines start rolling out, not all providers may have access in the beginning.

The rules are required to ensure that people who need vaccines can access them without any hardship to help put an end to the pandemic.

Under the rules insurers must pay out-of-network providers a "reasonable amount," which would be determined by the prevailing market rates that providers are charging health plans for the service. That may be the Medicare rate, the regulations note.

The rules cover more preventive services than just vaccines. They must also cover services that are "integral" to delivering preventive services, such as administrative costs.

Finally, if a preventive service, including a COVID-19 vaccine, is not billed separately from an office visit, and the primary purpose of the office visit is to deliver the recommended service or vaccine, the plan or insurer may not charge cost-sharing for the office visit.
 
COVID-19 tests by out-of-network providers
The new rules also set out the parameters for how health plans will pay out-of-network providers for COVID-19 diagnostic tests they perform on the latter's enrollees.

On testing, the CARES Act requires that:
  • Health care providers post on their websites the cash price or any lower negotiated price for COVID-19 diagnostic testing. The "cash price" is the charge that applies to a walk-in patient who pays cash for the service.
  • Health insurers pay out-of-network providers of COVID-19 diagnostic tests the price posted on the provider's website during the public health emergency.
 
The takeaway
If you sponsor a group health plan, you should communicate the new rules to your participating employees so that they are aware of the no out-of-pocket rules for COVID-19 preventive services. 
You should also keep up with the news about when vaccines will be rolled out in your area, so you can encourage your staff to get vaccinated.
​
The new rules will sunset at the end of the public health emergency. Currently, that's slated for Jan. 21, 2021, but will likely to be extended as it is unlikely a vaccine can be rolled out en masse by that time.

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