VT Insurance Bulletin #235
Health Insurance Coverage for Diagnostic Breast Imaging
State of Vermont
For consumer assistance:
Department of Financial Regulation
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888-568-4547
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Montpelier, VT 05620-3101
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www.dfr.vermont.gov
Insurance Bulletin #235
Health insurance coverage for diagnostic breast imaging
August 15, 2025
The purpose of this bulletin is to clarify the Department’s enforcement date of Act 94 of 2023
(H.621), An act relating to health insurance coverage for breast imaging, due to the potential
impact of Act 11 (S.30) of 2025, An act relating to updating and reorganizing the health
insurance statutes in 8 V.S.A. chapter 107. Under Act 94 of 2023, the Legislature amended 8
V.S.A. § 4095, Vermont’s mammography and breast imaging statute, to require coverage of
diagnostic mammography and breast imaging to detect the presence of breast cancer and other
abnormalities of the breast or breast tissue without member cost-sharing. This change is
effective January 1, 2026, as insurance plans are offered, issued or renewed but no later than
January 1, 2027.
Under Act 11 of 2025, the Legislature updated and reorganized 8 V.S.A. chapter 107,
introducing consistent language and terminology. Act 11 of 2025 incorporated the changes
made in Act 94 of 2023 and renumbered 8 V.S.A. § 4095 to 8 V.S.A. § 4095b.
The Legislature made Act 11 of 2025 effective September 1, 2025, including the changes to
Vermont’s mammography and breast imaging statute under Act 94 of 2023. Because the
Legislature intended that in Act 11 of 2025 “the substantive changes in other acts shall take
precedence over the technical changes in this act”, the Department has determined that the
effective date in Act 94 of 2023 takes precedence with respect to mammography and breast
imaging coverage. See Act 11 of 2025, § 32.
Therefore, the Department will not enforce Act 94 of 2023’s changes until January 1, 2026.
Inquiries about this bulletin should be directed to the Director of Health Insurance Regulation.
_________________________
Kaj Samsom, Commissioner of Financial Regulation
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Date
Docusign Envelope ID: 182A1FA3-51F7-4610-981C-AA9866411ECA
8/8/2025