For the time being, the federal government is picking up the cost of the vaccine, with providers being able to charge an administration fee for actually giving the shot. Regulations require that insured and self-funded group health plans must cover the cost of the office visit associated with the vaccine as long as the primary purpose of the visit is to receive the vaccine. And regardless of whether the vaccine is provided in-network or out-of-network, there must be no cost sharing involved.
Plan documents must be modified to reflect the availability of COVID-19 vaccinations and the change must be communicated to plan participants. In the case of self-funded plans, ERISA disclosure rules allow 210 days following the end of the previous plan year for the plan sponsor to issue this notification. With all the questions surrounding COVID-19 vaccines, it is recommended that employers be proactive in letting participants know that vaccinations will be covered.
Throughout the past year, organizations large and small have taken many steps to protect their workers. While those that could have people work remotely likely did, others provided PPE and modified workspaces to achieve social distancing. As states continue to loosen their restrictions and more and more people become eligible to receive a Covid-19 vaccine, employers that intend to bring people back to the workplace are working to determine how best to proceed. While very few seem to be requiring that workers get vaccinated, many employers are providing incentives to those who do.
Employees are Looking for Guidance
For employers that place a high priority on wellness, deciding how to proceed with vaccinations is critical. Employees look to their employer for meaningful health benefits and are likely expecting guidance in this area as well. Some HR directors have responded with information about the safety of available vaccines. Because people consume information differently, companies are using many forms of media to encourage vaccinations. Whether you use emails, webinars or videos featuring co-workers, persistence is paramount. One announcement won’t do the job – it will take a consistent campaign to overcome the skepticism that still exists. If you want to reinforce communication with an incentive, you might consider time off to get the shot, gift cards or several extra hours of pay.
Guidance recently released by the FDA outlining conditions for approving a Covid-19 vaccine includes a 50 percent benchmark, meaning that any vaccine must be at least 50 percent more effective than a placebo in preventing the disease. This is the same benchmark used annually to approve flu vaccines. In the announcement, Commissioner Stephen Hahn told a Senate panel that the FDA would not approve a vaccine for the general public without clinical evidence that it is both safe and effective.
In accordance with established FDA guidelines, an emergency authorization can move much quicker than a typical full approval, but would still require the vaccine maker to show through clinical studies that the vaccine produced lower levels of disease. Several clinical studies are underway, with one manufacturer having just initiated clinical testing by 60,000 adults.