MD Insurance Bulletin 23-13
COVID-19 Vaccination Coverage Requirements Reminder
BULLETIN 23-13
Date:
September 14, 2023
To:
All Health Insurers; Nonprofit Health Service Plans; and Health Maintenance
Organizations (“Carriers”)
Re:
COVID-19 Vaccination Coverage Requirements Reminder
On September 12, 2023, the Advisory Committee on Immunization Practices (ACIP) of the
Centers for Disease Control and Prevention (CDC) voted to recommend a COVID-19 vaccine
updated for 2023-2024 for everyone aged 6 months and older to protect against serious illness.
The Maryland Insurance Administration (MIA) is issuing this bulletin to remind carriers of the
applicable coverage requirements for COVID-19 vaccines under federal law.
Section 3203 of the CARES Act generally requires non-grandfathered group and individual health
benefit plans to cover, without cost-sharing requirements, any item, service, or immunization that
is intended to prevent or mitigate COVID-19 and that is: an evidence-based item or service that
has in effect a rating of “A” or “B” in the current recommendations of the United States Preventive
Services Task Force (USPSTF); or an immunization that has in effect a recommendation from the
ACIP of the CDC with respect to the individual involved. Coverage of a qualifying preventive
service for COVID-19 must begin 15 business days after the date on which an applicable
recommendation is made by USPSTF or ACIP.
The CARES Act does not require coverage of COVID-19 vaccines received from an out-ofnetwork provider, and, if coverage is provided, carriers may impose applicable out-of-network
cost-sharing. Whether or not a carrier is required under Maryland law to cover COVID-19
preventive services received from an out-of-network provider depends on the type of health benefit
plan contract, and whether the contract generally provides coverage for services received from outof-network providers.
KATHLEEN A. BIRRANE
Commissioner
TAMMY R. J. LONGAN
Acting Deputy Commissioner
WES MOORE
Governor
ARUNA MILLER
Lt. Governor
200 St. Paul Place, Suite 2700, Baltimore, Maryland 21202
1-800-492-6116 TTY: 1-800-735-2258
www.insurance.maryland.gov
2
As required by Section 3203 of the CARES Act, carriers must cover COVID-19 vaccines received
from an in-network provider, without cost-sharing, in accordance with the new ACIP
recommendation no later than October 3, 2023 (i.e., within 15 business days of September 12,
2023). However, the MIA encourages carriers to provide coverage as soon as administratively
feasible, rather than waiting 15 business days.
Questions about this Bulletin may be directed to the Life & Health Division of the Maryland
Insurance Administration at 410-468-2170.
KATHLEEN A. BIRRANE
Commissioner
By:
Signature on Original
_____________________
David Cooney
Associate Commissioner
Life and Health