COVID-19 Immunization Coverage

Last Updated: September 16, 2025 Date: September 16, 2025 To: Health Plan Issuers and Interested Parties From: Nathan Houdek, Commissioner of Insurance Subject: COVID-19 Immunization Coverage Bulletin20250916COVIDVaccineCoverage.pdf As directed by Governor Tony Evers in Executive Order #275 , the Office of the Commissioner of Insurance is issuing this bulletin to provide guidance to health insurers and governmental self-funded health plans regarding coverage requirements for the COVID-19 vaccine. Chief Medical Officer and State Epidemiologist for Communicable Diseases Dr. Ryan Westergaard has issued a standing medical order that serves as a prescription for eligible Wisconsinites to receive the COVID-19 vaccine. The Department of Health Services, based on evidence-based recommendations for vaccine administration, recently indicated that eligible Wisconsin Medicaid recipients can continue to receive COVID-19 vaccines without cost-sharing. Wis. Stat. 628.34 states that “no insurer may unfairly discriminate among policyholders by charging different premiums or by offering different terms of coverage." A coverage design that provides immunization coverage without cost-sharing for some but not all similarly situated insureds may constitute impermissible discrimination unless justified by sound actuarial or medical evidence. In consideration of the evidence-based guidance from the Department of Health Services and Chief Medical Officer Westergaard as well as state statute anti-discrimination provisions, the commissioner continues to expect that all governmental self-funded and fully insured group health plans and individual health plans will cover, without cost sharing, all costs associated with administration of COVID-19 vaccinations for all policyholders. Any questions concerning this bulletin may be directed to Sarah Smith, Director of Public Affairs, at Sarah.Smith2@wisconsin.gov .