WI Insurance Guidance on COVID-19 Vaccine Coverage

WI Insurance Bulletins

Published September 16th, 2025

Detected March 19th, 2026

Summary

The Wisconsin Office of the Commissioner of Insurance (OCI) issued guidance requiring health insurers and governmental self-funded health plans to cover COVID-19 vaccine administration costs without cost-sharing for all policyholders. This guidance aligns with an executive order and state anti-discrimination statutes.

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What changed

The Wisconsin Office of the Commissioner of Insurance (OCI) has issued guidance, effective September 16, 2025, directing all governmental self-funded and fully insured group health plans, as well as individual health plans, to cover the costs associated with the administration of COVID-19 vaccinations without imposing any cost-sharing on policyholders. This directive is based on Governor Tony Evers' Executive Order #275 and aligns with existing state anti-discrimination statutes (Wis. Stat. 628.34), which prohibit unfair discrimination among policyholders regarding coverage terms. The guidance emphasizes that providing coverage without cost-sharing for some but not all similarly situated insureds may be considered impermissible discrimination unless supported by sound actuarial or medical evidence.

Health plan issuers and interested parties must ensure their coverage designs comply with this expectation. Failure to provide COVID-19 vaccine administration coverage without cost-sharing could be viewed as discriminatory under state law. Insurers should review their policies and plan designs to confirm compliance. Questions regarding this bulletin should be directed to Sarah Smith, Director of Public Affairs, at Sarah.Smith2@wisconsin.gov.

What to do next

Review health plan designs to ensure coverage for COVID-19 vaccine administration costs without cost-sharing.
Confirm that no discriminatory practices are occurring regarding vaccine coverage terms.
Consult with legal counsel if plan designs require modification to comply with the guidance.

Source document (simplified)

OCI > Bulletin, September 16, 2025, COVID-19 Immunization Coverage

Bulletin, September 16, 2025, COVID-19 Immunization Coverage

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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.