Coverage for Vaccines

STATE OF VERMONT

DEPARTMENT OF FINANCIAL REGULATION

89 Main Street

Montpelier, VT 05620-3101

For consumer assistance:

[Banking] 888-568-4547

[Insurance] 800-964- 1784

[Securities] 877-550-3907

dfr.vermont.gov

Insurance Bulletin #238

Coverage for Vaccines

October 3, 2025

The purpose of this bulletin is to advise Vermont-regulated health plans as to the

Department of Financial Regulation’s (DFR) expectations regarding coverage for

vaccines.

Under 8 V.S.A. § 4042(b)(4)(A)(ii), 33 V.S.A. § 1811(d)(5)(A)(ii) and 42 U.S.C. § 300gg-

13(a)(2), all health plans operating in Vermont are required to cover immunizations “that

have in effect a recommendation from the Advisory Committee on Immunization

Practices of the Centers for Disease Control and Prevention [ACIP] with respect to the

individual involved.”

On September 19, 2025, ACIP recommended that for individuals six months of age or

older, “vaccination for COVID-19 be determined by individual decision-making [,]”

including “an emphasis that the risk-benefit of vaccination in individuals under age 65 is

most favorable for those who are at an increased risk for severe COVID-19. . .”1

Under 18 V.S.A. § 2, 18 V.S.A. § 126, and 26 V.S.A. Chapter 23, the Vermont

Department of Health (VDH) has authority to issue health orders to, among other things,

mitigate significant public health risks. VDH’s health orders are widely distributed,

known to health care practitioners and pharmacists, and made publicly available to

provide public health guidance to protect the health and wellness of Vermonters.

On September 17, 2025, VDH used the authorities of 18 V.S.A. § 2, 18 V.S.A. § 126,

and 26 V.S.A. Chapter 23 to issue a standing order authorizing qualified pharmacy

personnel to administer the 2025-2026 COVID-19 vaccine to individuals ages 5 years

and older

tioners and pharmacists, and made publicly available to

provide public health guidance to protect the health and wellness of Vermonters.

On September 17, 2025, VDH used the authorities of 18 V.S.A. § 2, 18 V.S.A. § 126,

and 26 V.S.A. Chapter 23 to issue a standing order authorizing qualified pharmacy

personnel to administer the 2025-2026 COVID-19 vaccine to individuals ages 5 years

and older. VDH also issued a health advisory notice to all Vermont health care providers

and pharmacies broadly recommending respiratory virus vaccines, including vaccines to

protect against COVID-19, influenza and respiratory syncytial virus (RSV).2 Based on

guidance from the Centers for Disease Control and Prevention (CDC), American

Academy of Pediatrics (AAP), American College of Obstetricians and Gynecologists

(ACOG), the American Academy of Family Physicians (AAFP) and the Infectious

Diseases Society of America (IDSA), VDH recommended vaccination against COVID-

19 for individuals six months of age or older who do not have a contraindication and

identified certain groups who are at higher risk that should receive a COVID-19 vaccine.

1 See U.S. Dept of Health & Human Servs Press Release, ACIP Recommends COVID-19 Immunization

Based on Individual Decision-making (Sep. 19, 2025).

2 See Vermont Dept of Health, Health Advisory, Updated Respiratory Virus Vaccine Guidance (Sep.18,

2025); Vermont Dept of Health, Standing Order for Administration of Vaccine, 2025-2026 COVID-19

Vaccine for Pharmacies, (Sep. 17, 2025).

Docusign Envelope ID: E719CE38-1921-4B12-8C2E-5B699684072C

Release, ACIP Recommends COVID-19 Immunization

Based on Individual Decision-making (Sep. 19, 2025).

2 See Vermont Dept of Health, Health Advisory, Updated Respiratory Virus Vaccine Guidance (Sep.18,

2025); Vermont Dept of Health, Standing Order for Administration of Vaccine, 2025-2026 COVID-19

Vaccine for Pharmacies, (Sep. 17, 2025).

Docusign Envelope ID: E719CE38-1921-4B12-8C2E-5B699684072C

VDH also recommended vaccination against RSV for older adults and infants and

seasonal vaccination against influenza for individuals six months of age or older who do

not have a contraindication.

Because VDH’s vaccination guidance is consistent with and informs individual and

shared clinical decision-making as recommended by ACIP, DFR expects Vermontregulated health plans to provide coverage for vaccines recommended by VDH and the

cost to administer vaccines, without member cost-sharing and without utilization review

for members who satisfy the recommended guidelines established by VDH for the

provision of immunizations in Vermont. Plans are also expected to publicize how eligible

members may access covered benefits for vaccines. Plans with prescription drug

formularies may limit access to vaccines to those specified on their plan formularies, if

there is at least one product on the plan formulary that will address each item on the

VDH recommended guidelines for vaccines. Plans may require that vaccines be

administered by a licensed health care provider under contract with the plan. 8 V.S.A. §

4067(b).

DFR also encourages third-party administrators (TPAs) of employer-sponsored health

plans to take steps aligned with this Bulletin. Employers should be made aware of the

VDH recommended vaccination guidelines, and TPAs should encourage employers to

voluntarily comply with this Bulletin.

Inquiries about this Bulletin should be directed to Sebastian Arduengo, Director

of Health Insurance Regulation

also encourages third-party administrators (TPAs) of employer-sponsored health

plans to take steps aligned with this Bulletin. Employers should be made aware of the

VDH recommended vaccination guidelines, and TPAs should encourage employers to

voluntarily comply with this Bulletin.

Inquiries about this Bulletin should be directed to Sebastian Arduengo, Director

of Health Insurance Regulation.

Kaj Samsom, Commissioner

Date

Docusign Envelope ID: E719CE38-1921-4B12-8C2E-5B699684072C

10/7/2025