Vaccine coverage in employer health plans for 2027

Compliance Calendar

Federal vaccine recommendations changed in 2025 and 2026, and the changes are being contested. Employer plans have a rule to follow, and for most employers the answer for 2027 is simpler than the headlines.

Key takeaways

• The ACA requires non-grandfathered plans to cover vaccines recommended by the CDC’s advisory committee, adopted by the CDC, with no cost sharing. Changes take effect for plan years beginning about a year after adoption.
• The recommendations have been challenged in federal court and the status can change quickly, so confirm the current position before relying on any one schedule.
• Insurers’ trade association has said member plans will cover vaccines recommended as of September 2025 through 2027. That promise does not bind self-funded plans.

The rule

Under the ACA, non-grandfathered group health plans must cover, with no cost sharing, immunizations recommended by the Advisory Committee on Immunization Practices (ACIP) and adopted by the CDC director. Coverage obligations generally begin with plan years starting one year after adoption, and continue while the vaccine stays on the schedule.

What changed

In 2025 the committee was reconstituted and made changes, including moving COVID-19 vaccination to individual decision-making, which still requires coverage, and altering recommendations for MMRV and the hepatitis B birth dose. Some of these changes have since been challenged in federal court, and the status can change quickly, so check the current position with your carrier and counsel before you rely on any of this.

States and insurers

Several states have issued their own guidance, and Michigan’s insurance department told insurers in October 2025 to keep covering COVID-19 vaccines without cost sharing in the individual and small group markets. State rules reach insured plans, not self-funded ones, which cover most people with employer coverage. The national insurers’ association has said its member plans will keep covering vaccines recommended as of September 1, 2025, including those recommended through shared decision-making, through the end of 2027.

What to do for 2027

• Ask your carrier, administrator and pharmacy benefit manager which immunization schedule they follow and have them confirm in writing
• If you are self-funded, decide whether to cover vaccines beyond the federal minimum and document the choice
• Check how vaccine administration and counseling visits are coded, so they are paid as preventive
• Do not promise employees coverage beyond what your carrier has confirmed

Questions we get

Does this affect grandfathered plans?

The preventive services mandate does not apply to grandfathered plans, though few remain. Ask your carrier whether yours is grandfathered.

What about employees who want vaccines the committee no longer recommends?

Plans may cover them voluntarily. A self-funded plan can add them. A fully insured plan follows the carrier’s policy and any state rules.

Will this change again?

Probably. Litigation and new committee action are both possible, which is why we suggest confirming coverage in writing each renewal.

Sources: ACA preventive services requirement (Public Health Service Act section 2713); KFF tracking of federal vaccine recommendation changes (2026); Michigan DIFS bulletin 2025-23-INS; AHIP statement on vaccine coverage. Status may have changed since publication.

Want your 2027 preventive coverage confirmed? Send us your renewal and we will get the carrier to confirm its vaccine policy in writing.