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Massachusetts Bulletin: Vaccine Coverage Without Cost-Sharing

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Published September 3rd, 2025
Detected February 7th, 2026
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Summary

The Massachusetts Division of Insurance and Department of Public Health issued Bulletin 2025-03 to clarify expectations for health insurers regarding vaccine coverage. Carriers are expected to cover all vaccines and their administration costs without cost-sharing or utilization management for individuals covered by Massachusetts-issued insured health plans.

What changed

Massachusetts Bulletin 2025-03, issued by the Division of Insurance and Department of Public Health, provides guidance to commercial health insurers, Blue Cross Blue Shield of Massachusetts, and Health Maintenance Organizations. The bulletin clarifies that carriers must cover all vaccines and their administration costs without cost-sharing or utilization management for individuals covered by Massachusetts-issued insured health plans who meet the Department of Public Health's recommended vaccination guidelines. Carriers are expected to update their Evidence of Coverage materials to reflect this policy.

Health insurers operating in Massachusetts must ensure their plans provide coverage for vaccines and their administration without any cost-sharing (deductibles, copayments, coinsurance) or prior authorization requirements, provided the vaccines align with the state's recommended guidelines. This applies to insured health plans and, by encouragement, to self-insured plans administered by carriers. Carriers must clearly communicate these benefits in all consumer-facing materials, including online information. While carriers may limit vaccine access to their formulary or network providers, at least one product must be available for each recommended vaccine, and providers must be within the plan's network.

Source document (simplified)

MAURA T. H EALEY MICHAEL T. CALJOUW GOVERNOR CO MMISSIONER KIM BERLEY DRISCO LL ROBERT H. GOLDS TEIN LIEUTENANT GOVERNOR COMMISSION ER Bulletin 2025- 03 TO: Commercial Health Insurers; Blue Cross Blue Shield of Massachusetts, Inc.; and Health Maintenance Organizations Offering or Renewing Insured Health Products in Massachusetts (“Carriers”) subject to M.G.L. c. 176O FROM: Michael T. Caljouw, Commiss ioner of Insurance Robert H. Goldste in, Commissione r of Public He alth DATE: September 3, 2025 RE: Coverage for Vaccines _____________________ __________ ____________ __________ ____________ __________ ___ This notice prov ides guida nce from the Massachuset ts Division o f Insurance (D OI) and Depa rtment of Public Health (DPH) to Carr iers about Massachusett s guidelines for vaccines, and t o clarify the DOI’s expectations regarding coverage for vaccines within Massachu setts-issued insured health plans. Under the provisions of M.G.L. c. 176O, §6(a), and t he DOI regulation for Managed Care Protect ions and Accreditation of Carriers, 211 CMR 52.00, in 211 CMR 52. 13, Ca rriers are expected to provide clear explanations within Evidence of Coverage materials t o persons covered within Massachusetts-issued insured health plans about benefits for vaccine s. The DOI also expects other Carrier com munication materials to imp art clear inform ation about vaccin e coverage. State Guideline s for Vaccines DPH is statuto rily mandat ed to attend to the health and wellbeing of peo ple in the Commonwealth (see M. G.L. c. 111, §§ 5, 6) and accordingly has issued recommended guidelines for vaccination [Vaccine information for healthcare and public health professionals | Mass.gov ]. DPH’s recommended guidelines are widely distributed, known to health care pr actitioners and pharmacists, and made publicly available to provide public heal th guidance to pro tect the hea lth and wellnes s of Massachusetts resid ents. Coverage for Va ccines Carriers are expe ct ed to pr ovide coverage for a l l vaccin es and the cost to administe r vaccines, with out cost- sharing and witho ut the use of any u tilization mana gement, for pe rsons covered und er Massachusetts-issued insured health plans who satisfy the recommended guidelines established by DPH for the provision of immunizations in Mass achusetts. C arriers are e xpected to upda t e al l Evidences of Coverage in acco rdance COMMON WEALTH OF MA SSACHUSETTS Office of Consumer Affairs and Business Regulation DIVISION OF INSURANCE One Federal Stre et, Suite 700 • B oston, MA 0211 0 (617) 521-7794 • T o ll-free (877) 563-4467 http://www.mass.gov/doi

Bulletin 2025- 03 September 3, 2025 Page 2 with 211 CMR 52.13, and to make clear in all onlin e in formation how eligible persons may access covered benefits for vacc ines. Carrier pro ducts w i th pre scription drug f ormularies m ay limit acc ess to vaccines to those specif ied on their plan formularies, provid ed that there is at least one product on the plan formulary t hat will address each item on the DPH recom mended guidelines fo r vaccines. Health plans that offer non-emergency coverage through a c losed network of providers may l imit access to those health care pract itioners or pharmacies that are part of their cl osed networks. Carriers Acting as Administrato rs When Carriers are acting as administrato rs for employment-sponsored, non-insured health benef it plans, the Division ex pects Car riers to encou rage plan spon sors to take steps that are consistent wi th this Bul letin 2025-03. Plan spo nsors should be made aware of the DPH r ecommended guidelines, and Carriers should encourage plan sponso r s to follow the provi sions of th is Bul letin for non-insured health benefit coverage in Massachuset ts. If you have any questions regarding this Bulletin, please contact Kevin Beagan, Deputy Commission er of the Health Care Access Bureau, Division of Insurance, at kevin.beagan@mass.go v; and Pejman Telebian, Director, Im munization Di vision, Department of Pub lic Heal th, at pejman.ta lebian@mass.gov.

Source

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Classification

Agency
State Insurance Departments (10 States)
Published
September 3rd, 2025
Instrument
Guidance
Legal weight
Non-binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Insurers
Geographic scope
State (Massachusetts)

Taxonomy

Primary area
Insurance
Operational domain
Compliance
Topics
Vaccines Public Health

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