MI DIFS Bulletin 2025-23-INS
COVID-19 Vaccinations ________________________________________
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STATE OF MICHIGAN
DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES
Bulletin 2025-23-INS
In the matter of:
COVID-19 Vaccinations
________________________________________/
Issued and entered
this 16th day of October 2025
by Anita G. Fox
Director
The Department of Insurance and Financial Services (the Department) issues this bulletin in accordance
with Executive Directive 2025-7, issued by Governor Gretchen Whitmer on September 17, 2025, to advise
that health insurers in the individual and small group markets must continue to cover COVID-19 vaccination
without cost-sharing.
MCL 500.3406bb lists items and services for which all insurers in the individual and small group markets
are required to provide coverage. As part of these requirements, under MCL 500.3406bb(1)(i)(ii), if the
federal Advisory Committee on Immunization Practices (ACIP) includes the immunizations in its
recommendations with respect to the individual involved, insurers in the individual and small group markets
are required to provide coverage for immunizations without cost-sharing requirements, except as otherwise
allowed under 45 CFR 147.130 (a)(2)(i), (ii), and (iii). ACIP is a committee within the United State Centers
for Disease Control that provides guidance and recommendations for vaccinations.
As of this date, the ACIP continues to recommend the COVID-19 vaccine, and, under subsection (1)(i),
insurance coverage for COVID-19 vaccinations therefore continues to be required without cost-sharing
except as otherwise allowed under 45 CFR 147.130 (a)(2)(i), (ii), and (iii).
Michigan Chief Medical Executive Standing Recommendation 2025-1 recognizes that any individual over
six months old who has not received a 2025-2026 Food and Drug Administration-approved or -authorized
COVID-19 vaccine “is considered to have an underlying condition that puts them at high risk for severe
outcomes from COVID-19 and is thus eligible to receive an age-appropriate dose.”
In the event of a future change to the ACIP’s recommendations, MCL 500.3406bb(9) states that “[a]ny
changes to the items and services required under subsection (1)(i) must take effect for the plan year that
begins on or after the date that is 1 year after the date the recommendation or guideline is issued.”
Consumers with questions about their health insurance may contact DIFS at Michigan.gov/DIFScomplaints
or by calling Monday to Friday from 8 a.m. to 5 p.m. at 877-999-6442.
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Any questions regarding this bulletin should be directed to:
Department of Insurance and Financial Services
Office of General Counsel
530 West Allegan Street, 7th Floor
Lansing, Michigan 48933
Toll Free: (877) 999-6442
/s/
_________________________________________
Anita G. Fox
Director