Q&A: Employers and the COVID-19 Vaccine
Q: Are employer-sponsored health plans required to cover COVID-19 vaccinations?
A: Yes, generally all non-grandfathered health plans are required to cover the costs of immunizations that are considered preventive services by the Patient Center Outcomes Research Institute (PCORI). The Coronavirus Aid, Relief, and Economic Security (CARES) Act requires the COVID-19 vaccination to be covered within 15 business days after the recommendation is made by PCORI for it to be considered a preventive service.
NOTE: This coverage must be provided for both in-network and out-of-network providers during the COVID-19 public health emergency.
Q: Can employers require vaccinations?
A: Yes, employers can require employees to get vaccinated. However, make sure you consider how the following will interact with that approach:
- State laws
- Americans with Disabilities Act
- Collective Bargaining Agreements
- EEOC Guidance
Q: Are COVID-19 vaccinations required by law?
A: No, COVID-19 vaccinations are not required by law, and employers are not required to implement vaccination mandates on their employees.
Q: At this time, who is eligible to receive a vaccination?
A: The COVID-19 vaccination is available in phases of prioritized groups. This list will expand with time to include more groups of the population, which you can review periodically here.
Currently, the State of Michigan is permitting vaccinations for the following groups:
- Childcare and Pre-K through high school staff
- Healthcare workers
- Long-term care workers
- Residents who are 65 and older
- Essential workers, including first responders, corrections workers, and inspectors
- Congregate Care Facilities, such as homeless shelters
Q: Where in Michigan can I receive the COVID-19 vaccine?
Q: What are some additional considerations and management tips for schools at this time?
- Plan scheduling logistics: Determine how to best manage your employees’ schedules. Depending on what works best for your district, you may consider designating day-time hours for employees to receive vaccinations. These designated times may be staggered or all in one based on what is most beneficial to your district and your staff.
- Check in with your carrier or TPA: Ensure your plan documents and certificates of coverage will handle vaccination claims as expected.
- Communicate: Proactively communicate with your staff about the availability of the COVID-19 vaccination and how they can leverage your support to gain access.
- Collaborate: Work closely with your benefit administrators to navigate the fast-paced changes brought on by COVID-19 to ensure you are administering your plans in accordance with your plan documents and accurately communicating with your employees about COVID-19 entitlements and vaccination access.