COVID-19 Update


JTS Compliance
December 7, 2020

With a COVID-19 vaccine expected before the end of 2020, the Centers for Medicare & Medicaid Services (CMS) along with the Departments of Labor and the Treasury, is laying the groundwork now to ensure immediate coverage and payment for preventive COVID-19 vaccination for individuals covered by group health plans.

In an Interim Final Rule with Comment Period (IFC) issued on October 28, 2020 by CMS, the IFC included provisions for implementing the requirement of the CARES Act that non-grandfathered group health plans must provide coverage, without cost sharing regardless of whether an in-network or out-of-network provider delivers such services, for qualifying coronavirus preventive services, which includes COVID-19 immunizations.

Any COVID-19 vaccine must still be recommended by the U.S. Preventive Health Services Task Force and the Center for Disease Control & Prevention’s Advisory Committee on Immunization Practices (ACIP) before it is covered with no cost-sharing.  Under normal circumstances, health plans would have one year from the recommendation to cover the service, but the CARES Act cuts that time down to 15 days.

Expected prices are in line with the annual flu vaccine.  Pfizer and BioNTech have set the initial price of $39 per patient. Moderna’s price is expected to be $50 per patient.  

Health officials expect that the first group of individuals to receive any vaccine will be doctors and nurses on the front lines of treating patients, followed by the elderly and individuals with health problems that put them at greater risk for Covid-19 complications.  It is thought that the general public will not be able to receive a vaccine until the spring or summer of 2021.

Please contact JTS if you have any questions or need additional information.