HI Commissioner's Memorandum 2025-7H
COVID-19 Vaccination Coverage
JOSH GREEN, M.D.
GOVERNOR | KE KIAʻĀINA
SYLVIA LUKE
LIEUTENANT GOVERNOR | KA HOPE KIAʻĀINA
STATE OF HAWAII | KA MOKUʻĀINA ʻO HAWAIʻI
DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS
KA ʻOIHANA PILI KĀLEPA
INSURANCE DIVISION
335 MERCHANT STREET, ROOM 213, HONOLULU, HAWAII 96813
P.O. BOX 3614, HONOLULU, HAWAII 96811
Phone Number: (808) 586-2790
Fax Number: (808) 587-6714
cca.hawaii.gov/ins/
NADINE Y. ANDO
DIRECTOR | KA LUNA HOʻOKELE
SCOTT K. SAIKI
INSURANCE COMMISSIONER
September 11, 2025
MEMORANDUM 2025-7H
To:
All Health Insurance Companies, Mutual Benefit Societies, and Health
Maintenance Organizations Authorized to Write Health Insurance in the
State of Hawaii
From:
Scott K. Saiki, Insurance Commissioner
Subject:
COVID-19 Vaccination Coverage
This Memorandum is directed to all insurance companies, mutual benefit societies, and health
maintenance organizations authorized to write health insurance in the State of Hawaii
(collectively, “health insurers”).
It remains vital to public health that individuals across all age groups maintain access to COVID-
19 vaccinations to prevent severe illness and hospitalization.
Accordingly, the Commissioner expects health insurers to continue providing COVID-19
vaccination coverage for individuals aged six months and older without imposing cost-sharing
requirements and utilization management even for off-label indications.
Given that smaller healthcare providers and pharmacies may face financial strain in procuring
and storing vaccines, the Insurance Division also expects health insurers to work with providers
and the Department of Health to ensure a sufficient supply of COVID-19 vaccine to meet
demand, reduce the financial burden on smaller entities, and facilitate vaccine administration
throughout the state particularly for groups at increased risk of severe infection.
Health insurers are expected to continue uninterrupted access to COVID-19 vaccines and to
communicate clearly with their members regarding ongoing coverage.
The Insurance Division will continue to monitor insurer challenges and may issue further
guidance as needed at http://cca.hawaii.gov/ins/.
Please contact the Insurance Division at ihealth@dcca.hawaii.gov or (808)-586-2790 if you
have any questions regarding this matter.