A Toolkit of resources to help plan sponsors of group health plans, plan administrators, service providers, and their advisors understand the legal obligations and practical considerations regarding plan-related COVID-19 testing and vaccination requirements. The Toolkit also includes resources addressing certain plan-related relief provisions issued by the federal administrative agencies in response to COVID-19.
In response to COVID-19, the disease that results from SARS-CoV-2 and its variants, Congress enacted several requirements for group health plans and health insurers regarding COVID-19 testing and vaccinations. In addition, the Departments of Labor (DOL), Health and Human Services (HHS), and Treasury (collectively, Departments) issued COVID-19-related compliance relief for plans and insurers, which included extended compliance deadlines for some requirements.
As the requirements and guidance for COVID-19 testing, vaccinations, and related relief evolved, plan sponsors, plan administrators, service providers, and their advisors have needed to ensure that their health plan terms, related policies, and participant communications are legally compliant. Doing so helped these entities avoid enforcement actions by the Departments and litigation.