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On September 18 and 19, 2025, the Advisory Committee on Immunization Practices ("ACIP") of the Centers for Disease Control and Prevention ("CDC") revised its recommendations regarding the COVID-19 vaccine and the combined measles, mumps, rubella, varicella ("MMRV") vaccine. ACIP considered changes to the Hepatitis B vaccine requirement, but did not approve any changes to the existing recommendation. ACIP recommendations are generally not effective until they have been adopted by the Director of the CDC (the current CDC Director is Acting).
ACIP's recommendations are important for group health plans and health insurance issuers because the Affordable Care Act requires plans and issuers to cover without cost-sharing immunizations for routine use in children, adolescents, and adults that have been adopted by ACIP. As relevant here, if ACIP no longer recommends a vaccine for certain individuals, plans and issuers are no longer required to cover the vaccine without cost-sharing for those individuals after the end of the plan or policy year in which the ACIP change is effective.
Assuming the Acting CDC Director adopts the ACIP's September 18 and 19 recommendations this year, the implications for plans and issuers of the ACIP's revised recommendations are as follows:
- MMRV Vaccine
- Plans may, but are not required to, stop covering the combined vaccine without cost sharing for children under age four after the end of the current plan year.
- Plans must continue covering the combined vaccine at 100% for children ages four and older if parents prefer the vaccine.
ACIP voted to continue the existing recommendation that children under age four should continue to receive the measles, mumps and rubella vaccine ("MMR") and varicella vaccine as two separate vaccines, so plans and issuers must continue covering the MMR vaccine at 100% starting at age 12-15 months and the varicella vaccine at 100% starting at age 12-15 months.
- COVID-19 Vaccine
- Plans must continue covering the COVID-19 vaccine at 100% for individuals ages 6 months and older based on "individual decision-making" (individual decision-making is referred to on the CDC's adult and child immunization schedules as vaccination based on shared clinical decision-making, which references providers including physicians, nurses, and pharmacists).
The Department of Health and Human Services ("HHS") published a statement related to the ACIP meeting noting that "HHS will examine all insurance coverage implications following today's ACIP recommendation, prior to a final decision on adoption by the Acting Director." Thus, we expect to receive further information from HHS.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
