Chaptered Assembly Bill 144 and Coverage of Preventive Care Services

RICARDO LARA

CALIFORNIA INSURANCE COMMISSIONER

BULLETIN 2025-14

TO:

All Health Insurers1

FROM:

Insurance Commissioner Ricardo Lara

DATE:

September 30, 2025

RE:

Chaptered Assembly Bill 144 and Coverage of Preventive Care Services

On September 17, 2025, Governor Gavin Newsom signed Assembly Bill (AB) 144

(Assembly Committee on Budget, Stats. 2025, Ch. 105). In part, AB 144 ensures

California consumers have continued access to necessary preventive care services.

AB 144 directs health insurers to cover preventive care items and services, including

immunizations, if such care was recommended by existing federal bodies2 as of

January 1, 2025, or is recommended by the California Department of Public Health

(CDPH). AB 144 is an urgency measure that went into effect immediately.

This Bulletin outlines the obligations of health insurers to cover preventive care items

and services prior to enactment of AB 144 and summarizes AB 144’s new requirements

regarding coverage of preventive care items and services. The Bulletin also highlights

recent recommendations by CDPH regarding immunizations to protect against

coronavirus disease 2019 (COVID-19), respiratory syncytial virus (RSV), and influenza.

I. Background

California Insurance Code (CIC) sections 10110.7, 10110.75, 10112.2, 10123.5, and

10123.55 each include requirements related to coverage of preventive care. State law

requirements prior to the adoption of AB 144 are detailed in this section.

A. Previous CIC section 10112.2 (immunizations and preventive services generally)

CIC section 10112.2 specifically requires health insurers to cover preventive care items

and services that have an “A” or “B” recommendation from the United States Preventive

Services Task Force (USPSTF)

rage of preventive care. State law

requirements prior to the adoption of AB 144 are detailed in this section.

A. Previous CIC section 10112.2 (immunizations and preventive services generally)

CIC section 10112.2 specifically requires health insurers to cover preventive care items

and services that have an “A” or “B” recommendation from the United States Preventive

Services Task Force (USPSTF).

With respect to women, infants, children, and adolescents, insurers must cover without

cost-sharing the evidence-informed preventive care services and screenings contained

in the comprehensive guidelines supported by the United States Health Resources and

1 This Bulletin applies to all health insurers as defined by California Insurance Code section 106(b),

including student health insurance, as defined under CIC section 10965.03.

2 E.g., the Advisory Committee on Immunization Practices (ACIP) of the federal Centers for Disease

Control and Prevention (CDC), the United States Preventives Services Task force (USPSTF), or the

United States Health Resources and Services Administration (HRSA).

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September 30, 2025

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Services Administration (HRSA).3 Likewise, those sections require insurers to cover

immunizations recommended by the Advisory Committee on Immunization Practices

(ACIP) of the federal Centers for Disease Control and Prevention (CDC). These

coverage requirements include preventive care items and services, including

immunizations. Insurers must cover such services without cost-sharing, consistent with

section 10112.2.

B

SA).3 Likewise, those sections require insurers to cover

immunizations recommended by the Advisory Committee on Immunization Practices

(ACIP) of the federal Centers for Disease Control and Prevention (CDC). These

coverage requirements include preventive care items and services, including

immunizations. Insurers must cover such services without cost-sharing, consistent with

section 10112.2.

B. Previous CIC sections 10110.7 (COVID-19 preventive services and

immunizations) and 10110.75 (declared public health emergency)

CIC sections 10110.7 and 10110.75 specifically include coverage requirements for

items and services to prevent or mitigate COVID-19 or any other disease for which the

Governor has declared a public health emergency. Insurers must cover such services

without cost-sharing or utilization management in many cases, consistent with sections

10110.7 and 10110.75.

C. Previous CIC sections 10123.5 and 10123.55 (childhood and adolescent

immunizations and preventive services)

CIC sections 10123.5 and 10123.55 provided that group health policies must cover

periodic health evaluations, immunizations, and laboratory services as contained in the

Recommended Childhood Immunization Schedule/United States, jointly adopted by the

American Academy of Pediatrics, the ACIP, and the American Academy of Family

Physicians.

D. Recent Changes to FDA Approval for COVID-19 Vaccines

In August, the U.S. Food and Drug Administration (FDA) released approvals for several

COVID-19 vaccines.4 Unlike previous approvals, the FDA approved these vaccines only

for individuals 65 years of age and older or for people who are younger than 65 but

have at least one underlying condition that puts them at high risk for severe outcomes

from COVID-19.

II

FDA Approval for COVID-19 Vaccines

In August, the U.S. Food and Drug Administration (FDA) released approvals for several

COVID-19 vaccines.4 Unlike previous approvals, the FDA approved these vaccines only

for individuals 65 years of age and older or for people who are younger than 65 but

have at least one underlying condition that puts them at high risk for severe outcomes

from COVID-19.

II. AB 144 Provides that the Federal Recommendations in Effect on January 1,

2025 Serve as a Baseline, and Allows the California Department of Public

Health to Supplement those Recommendations

AB 144, available at this link, amends CIC sections 10110.7, 10110.75, 10112.2,

10123.5, and 10123.55. These amendments took effect immediately on September 17,

2025, when the Governor signed AB 144.The requirements of AB 144 are set forth

below.

3 Insurance Code section 10112.2.

4 The approved COVID-19 vaccines are: MNEXSPIK and SPIKEVAX (both manufactured by Moderna Tx,

Inc.); COMIRNATY (manufactured by BioNTech Manufacturing GmbH); and NUVAXOVID (manufactured

by Novavax, Inc.).

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September 30, 2025

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A

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A. Amendments to CIC section 10112.2 (immunizations and preventive services

generally)

CIC section 10112.2, as amended by AB 144, requires health insurers to cover, without

cost-sharing all items, services integral to the provision of preventive items, and

services with a USPSTF “A” or “B” recommendation, a recommendation by ACIP and/or

those items and services consistent with HRSA guidelines as of January 1, 2025.5

Health insurers must continue to cover these services even if the USPSTF, ACIP, or

HRSA remove or downgrade their recommendations. The AB 144 amendments allow

CDPH to modify or supplement the USPSTF, ACIP, and HRSA recommendations and

require insurers to cover the modifications or supplements within 15 business days after

CDPH publishes the updated recommendations.

B. Amendments to CIC sections 10110.7 (COVID-19 preventive services and

immunizations), and 10110.75 (declared public health emergencies)

CIC section 10110.7, as amended by AB 144, requires health insurers to cover, without

cost-sharing or utilization management all items, services integral to the provision of

preventive items, and services to prevent or mitigate COVID-19 and with a USPSTF “A”

or “B” recommendation, or a recommendation by ACIP as of January 1, 2025. The

AB 144 amendments allow CDPH to modify or supplement the USPSTF, and ACIP

recommendations and require insurers to cover the modifications or supplements within

15 business days after CDPH publishes the updated recommendations

ion of

preventive items, and services to prevent or mitigate COVID-19 and with a USPSTF “A”

or “B” recommendation, or a recommendation by ACIP as of January 1, 2025. The

AB 144 amendments allow CDPH to modify or supplement the USPSTF, and ACIP

recommendations and require insurers to cover the modifications or supplements within

15 business days after CDPH publishes the updated recommendations.

Similarly, section 10110.75, as amended by AB 144, requires health insurers to cover,

without cost-sharing or utilization management, all items, services integral to the

provision of preventive items, and services to prevent or mitigate a disease when the

Governor of the State of California has declared a public health emergency due to that

disease with a USPSTF “A” or “B” recommendation, or a recommendation by ACIP as

of January 1, 2025. The AB 144 amendments allow CDPH to modify or supplement the

USPSTF and ACIP recommendations and require insurers to cover the modifications or

supplements within 15 business days after CDPH publishes the updated

recommendations. In addition to the CDPH recommendations and the USPSTF

recommendations, the AB 144 amendments also require that coverage of an item,

service, or immunization must be covered 15 business days after the the American

Academy of Pediatrics, the American College of Obstetricians and Gynecologists, the

American Academy of Family Physicians, or CDPH makes a recommendation relating

to the item, service, or immunization.

C. Amendments to CIC sections 10123.5 and 10123.55 (childhood and adolescent

preventive services and immunizations)

5 Please note that the HRSA guidelines were updated in December 2024 for Screening and Counseling

for Intimate Partner and Domestic Violence, Breast Cancer Screening for Women at Average Risk, and a

new guideline for Patient Navigation Services for Breast and Cervical Cancer Screening was introduced

sections 10123.5 and 10123.55 (childhood and adolescent

preventive services and immunizations)

5 Please note that the HRSA guidelines were updated in December 2024 for Screening and Counseling

for Intimate Partner and Domestic Violence, Breast Cancer Screening for Women at Average Risk, and a

new guideline for Patient Navigation Services for Breast and Cervical Cancer Screening was introduced.

Because these changes occurred prior to January 1, 2025, health insurers must incorporate these

changes into practice for the 2026 plan year.

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September 30, 2025

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The amendments to CIC sections 10123.5 and 10123.55 require group health insurance

products to cover the childhood periodic health evaluations, immunizations, and

laboratory services contained in the Recommended Childhood Immunization

Schedule/United States, jointly adopted as of January 1, 2025, by the American

Academy of Pediatrics, ACIP, and the American Academy of Family Physicians.6 CDPH

may modify or supplement such recommendations taking into consideration guidance

and recommendations from additional medical and scientific organizations, including,

but not limited to, the American Academy of Pediatrics, the American College of

Obstetricians and Gynecologists, and the American Academy of Family Physicians.

D. Health Savings Account-eligible High-Deductible Health Plans

For insureds in health savings account (HSA)-eligible high-deductible health plans

(HDHPs), insurers must cover preventive services in conformance with AB 144, unless

doing so would disqualify the HDHP from eligibility for an HSA pursuant to Internal

Revenue Code section 223 (26 U.S.C. § 223).

III

n Academy of Family Physicians.

D. Health Savings Account-eligible High-Deductible Health Plans

For insureds in health savings account (HSA)-eligible high-deductible health plans

(HDHPs), insurers must cover preventive services in conformance with AB 144, unless

doing so would disqualify the HDHP from eligibility for an HSA pursuant to Internal

Revenue Code section 223 (26 U.S.C. § 223).

III. CDPH Immunization Recommendations

On September 17, 2025, CDPH issued guidance regarding COVID-19, influenza, and

RSV immunizations. That guidance can be found here and provides as follows:

• COVID-19

o Children:

•

All children 6-23 months;

•

All children 2-18 years with certain risk factors; and,

•

All children with close contact with others with risk factors; All children

who choose protection.

o Adults:

o All adults age 65 years or older;

o All adults ages 18-64 years with certain risk factors;

o All adults with close contact with others with risk factors; and,

o All adults who choose protection.

o Pregnancy:

o All planning, pregnant, postpartum, or lactating.

• Influenza

o Children:

o All children 6 months or older.

o Adults:

o All adults 18 years or older.

o Pregnancy:

o All planning, pregnant, postpartum, or lactating.

• RSV

6 Please note that any changes made by ACIP after January 1, 2025, including the removal or

modification of prior recommendations for vaccinations and the timing of their administration, shall not be

considered when determining health insurance coverage.

dren 6 months or older.

o Adults:

o All adults 18 years or older.

o Pregnancy:

o All planning, pregnant, postpartum, or lactating.

• RSV

6 Please note that any changes made by ACIP after January 1, 2025, including the removal or

modification of prior recommendations for vaccinations and the timing of their administration, shall not be

considered when determining health insurance coverage.

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September 30, 2025

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o Children:

•

All children 8 months or younger; and,

•

All children 8-19 months with risk factors.

o Adults:

•

All adults 75 years or older; and,

•

All adults 50-74 years with risk factors.

o Pregnancy:

•

Pregnant between 32-36 weeks gestational.

Health insurers must cover CDPH-recommended immunizations with the cost-sharing

and utilization management limitations consistent with AB 144. If the immunization is not

already encompassed within recommendations by ACIP or the USPSTF, health insurers

must begin covering the immunization by October 8, 2025, which is 15 business days

following CDPH’s publication of its recommendation.

Please note, the FDA currently recommends COVID-19 immunizations only for people

who are 65 years of age or older, or for younger people with at least one underlying

condition that puts them at greater risk for COVID-19. Notwithstanding the FDA’s

recommendation, per AB 144, health insurers must cover COVID-19 immunizations per

CDPH’s recommendations even if doing so could be considered “off label.”

If you have questions regarding this Bulletin, please contact Stesha Hodges, Chief of

the California Department of Insurance’s Health Equity and Access Office, at

Stesha.Hodges@insurance.ca.gov.