On Friday, October 29, 2021, the US Food & Drug Administration (FDA) granted emergency use authorization (EUA) of the Pfizer/BioNTech COVID-19 vaccine in children ages 5 through 11.  The dose is one-third that provided to adults and children ages 12 and up, and it uses a smaller needle, so it’s being packaged in smaller vials to avoid any confusion.  However, it is still a two-dose primary regimen at least three weeks apart.  This is based solely on the child’s age the day of vaccination, not their weight or other variables.

The Centers for Disease Control and Prevention (CDC) followed up the FDA’s EUA with their own formal approval on Tuesday, November 2.  The CDC offers parents several pointers, such as not giving your child a pain reliever in advance of the injection and having your child stay with the provider for 15-30 minutes to observe any possible side effects.

Fifteen million doses have already been specially packed and shipped to help meet the need for vaccinating 28 million children in this age range.  It’s expected parents can schedule their children for vaccines starting the week of November 8.

Non-grandfathered plans must immediately cover this without cost-sharing in- and out-of-network.  Note that vaccines are still fully paid for by the federal government, so plans are paying for the administration of the vaccine rather than the vaccine itself.  In the case of children under 12, this cost might be more than plans are used to because a primary outlet for vaccine administration will be via pediatricians.  Local children’s hospitals, pharmacies, school clinics, and other health care settings are also being lined up to be able to facilitate the vaccinations, but surveys show parents are indicating a preference to get these administered at the pediatrician’s office.

Once the public health emergency is declared over by the Department of Health and Human Services (HHS), then non-grandfathered plans may apply cost-sharing for vaccines obtained out-of-network so long as there is adequate access for members to get vaccines in-network.  Note HHS extended the COVID-19 public health emergency on October 15 to last at least another 90 days (taking us to mid-January 2022).

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.