On Thursday, December 2, 2021, the White House announced President Biden’s plans to combat COVID-19 this winter.  The action plan includes the following:

  • Boosters for All Adults
  • Vaccinations to Protect Our Kids and Keep Our Schools Open
  • Expanding Free At-Home Testing for Americans
  • Stronger Public Health Protocols for Safe International Travel
  • Protections in Workplaces to Keep Our Economy Open
  • Rapid Response Teams to Help Battle Rising Cases
  • Supplying Treatment Pills to Help Prevent Hospitalizations and Death
  • Continued Commitment to Global Vaccination Efforts
  • Steps to Ensure We Are Prepared for All Scenarios

Here are the categories most relevant to employer health plans.

  • Already Effective: Free Vaccines and Boosters
    • At this point, all non-grandfathered health plans must cover without cost sharing:
      • Primary vaccinations and boosters for everyone age 18+
      • Primary vaccinations for all children age 5+
    • The Biden administration continues to encourage all employers to provide paid time off to get vaccinated and recover from vaccines even if not mandated by a state or local order (note, however, that the ERC and FFCRA federal tax credits have expired)
  • Coming in January: Free At-Home Testing
    • “The Departments of Health and Human Services, Labor and the Treasury will issue guidance by January 15th to clarify that individuals who purchase OTC COVID-19 diagnostic tests will be able to seek reimbursement from their group health plan or health insurance issuer and have insurance cover the cost during the public health emergency.”
    • Group health plans should prepare to not only cover at-home testing in the new year but to communicate with employees how that will work with your health plan, such as requirements to submit receipts and limits on number of tests per household member as allowed under the upcoming rules.
    • New guidance outlines the appropriate way for at-home kits to be used in an employment setting. “In the case of self-testing being performed in a setting other than home (e.g. workplace), if the individual performs and interprets their own test and then shows their test result to someone else (e.g., employer) as proof of their result, we do not consider this to be interpretation or reporting, since the individual has performed and interpreted their own test in accordance with the instructions for use of that particular test. In this case, CLIA certification is not required.”
  • Coming Soon: Coverage of Visits to be Prescribed Treatment Pills
    • As these new treatments continue to be developed and reviewed, the administration is ensuring any new COVID-19 treatment pills that meet FDA’s standards will be accessible to all Americans. The federal government has contracts to buy millions of pills up front, so the costs may be minimal to health plans for a while.
    • However, as these are designed to be taken at home after symptoms begin, chances are the individual’s visit to diagnose COVID-19 has already been paid in full by the health plan and they’ll need an extra provider or telehealth visit to obtain a prescription following onset of symptoms.
    • Both Merck and Pfizer are seeking emergency use authorization.

Written by: KC Rippstein & Michelle Cammayo

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.

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