Joint Letter to HHS Secretary Becerra on COVID-19 Vaccine Coverage

September 27, 2023
The Honorable Xavier Becerra
U.S. Department of Health & Human Services
200 Independence Avenue, S.W.
Washington, DC 20201

Dear Secretary Becerra:

Thank you for your commitment and dedication to ensure that every American has access to the updated COVID-19 vaccine without cost sharing. We steadfastly share this commitment and dedication. In response to your September 22nd letter, we are writing as representatives of the health insurance industry to share our actions to increase COVID-19 vaccine access, educate consumers and remove barriers. We recognize the critical public health importance of getting as many Americans as possible vaccinated.

Throughout this transition to traditional public and private reimbursement, our members prepared and have been working tirelessly to overcome systems challenges and increase access. We value the collaboration with your teams as we work together to continue to expand access to the updated COVID vaccines through more routine channels. You have our commitment that health insurers are fully covering the new COVID-19 shots, as required, with no cost sharing when consumers access them from a network provider or receive them through an out-of-network provider when in-network options are unavailable.

In collaboration with the Administration, our industry has been preparing for the new COVID-19 vaccine distribution system for months to facilitate patient access to this critical preventive service. These preparations allowed us to quickly resolve technical and coding issues as they arose. We appreciate your teams’ assistance in rapidly identifying problems. We continue to closely monitor our member reports of any technical or coding barriers to vaccine coverage. At this time, we understand that systemic technical issues have been largely, if not completely, resolved and are not limiting patient access to vaccines. Should further issues arise, we stand ready to swiftly implement system improvements.

As you pointed out in your letter, the transition of COVID vaccines to the commercial market has changed how and where people can access these vaccines. In preparation to educate consumers, the health insurance industry has updated public-facing resources and educated customer service agents to help guide members on their options, and we will continue to calibrate our communications and tools to meet consumer needs. For consumers who experienced claims denials or other hurdles in the initial days of vaccine availability, health plans are proactively contacting members and connecting them to in-network providers with available no-cost sharing COVID vaccine. Plans continue to work closely with pharmacy networks to guide members to available appointments to get their COVID vaccines and to avoid any claims denials or other barriers to access. We look forward to continued collaboration with your teams as health plans work with consumers to select in-network providers whenever possible.

We fully understand the urgency and importance of quickly resolving any challenges that a consumer may face getting vaccinated. As vaccines become more available across the country, we will continue to proactively educate consumers on where they can find available vaccines in-network without cost sharing. We all share your goal that every American who seeks the updated COVID vaccine may receive it quickly, conveniently, and without cost-sharing, so that they may protect themselves, their loved ones, and their communities. We will continue to work with the Administration, providers, and pharmacies to make this a reality in the coming days.

If additional challenges arise, you have our commitment that we will work tirelessly to address and resolve them immediately.

Thank you in advance for your engagement to date and your commitment to work with us to address these shared challenges. Please contact us if you have any questions.



Alliance of Community Health Plans
Association for Community Affiliated Plans
Blue Cross Blue Shield Association