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COVID-19 Testing, Vaccination, and Relief Provisions for Group Health Plans Toolkit
Practical Law Toolkit w-035-4619 (Approx. 6 pages)
COVID-19 Testing, Vaccination, and Relief Provisions for Group Health Plans Toolkit
by Practical Law Employee Benefits & Executive Compensation
| Maintained • USA (National/Federal) |
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.
Although the national emergency (NE) and public health emergency (PHE) associated with COVID-19 expired in May 2023, at least some of the COVID-era benefits provisions continue to apply. Post-PHE, for example, plans and insurers must continue to cover "qualifying coronavirus preventive services—which includes coverage for COVID-19 vaccines—without cost-sharing (see Article, COVID-19 Public Health Emergency (PHE) and National Emergency (NE) Wind-Down: Health and Welfare Plan Compliance Issues).
The resources in this Toolkit are intended to help plan sponsors, plan administrators, service providers, and their advisors:
- Understand the various plan-related statutory requirements (including under the Families First Coronavirus Response Act (FFCRA) and Coronavirus Aid, Relief, and Economic Security Act (CARES Act)) and implementing guidance governing COVID-19 testing, vaccinations, and certain COVID-19 relief provisions.
- Avoid expensive litigation, including claims by health providers seeking reimbursements for COVID-19 testing consistent with implementing guidance.