Colorado Issues Coverage Statements on Covid-19 Vaccines, Biomarker Tests, and PANs/PANDAs

December 02, 2025

On September 11, 2025, the Colorado Division of Insurance (DOI) adopted Emergency Regulation 25-E-04 requiring carriers to cover COVID-19 vaccines as a preventive service without cost-sharing. This regulation aligns with Public Health Order 25-01, issued September 3, 2025, which authorizes trained healthcare professionals – such as nurses and pharmacists – to administer vaccines under protocol. The Public Health Order also allows Coloradans to receive vaccines from participating providers and pharmacies without an individual prescription. However, costs may still apply based on a person’s insurance coverage.

On November 19, 2025, the DOI issued Bulletin B-4.155 regarding coverage of biomarker testing in health benefit plans. The Bulletin clarifies the DOI’s interpretation of existing coverage requirements on biomarker testing for diagnosis, treatment, appropriate management, and ongoing monitoring of a covered person’s disease or condition by articulating that:

• Coverage of biomarker testing is required for large group health benefit plans issued or renewed on or after January 1, 2025.
• Under 2024 Colorado Senate Bill 24-124, coverage for biomarker testing that is medically necessary and supported by medical/scientific evidence is required by all small group and individual plans. The DOI’s position is that these biomarker tests are not in addition to the benefits provided by Colorado’s benchmark plan.

The Bulletin notes that if the federal HHS Department later requires Colorado to defray additional costs, the DOI will notify the relevant state legislative health committees.

On November 19, 2025, the Colorado DOI also issued Bulletin B-4.154 concerning coverage of pediatric neuropsychiatric syndrome (PANs) and pediatric autoimmune neuropsychiatric disorder associated with streptococcal infections (PANDAs) in health benefit plans. The Bulletin clarifies the DOI’s position on 2024 Colorado House Bill 24-1382 that:

• Coverage of the prophylaxis, diagnosis, and treatment of PANs/PANDAs is required for large group plans issued or renewed on or after January 1, 2025.
• Coverage for prophylaxis, diagnosis, and treatment with antibiotics, medication therapies, and behavioral health therapies to manage neuropsychiatric symptoms are required for small group and individual plans. However, coverage of treatment using intravenous immunoglobulin and plasma exchange is in addition to benefits in the state’s EHB benchmark plan and, therefore, individual and small group plans are not required to provide this coverage.

The Bulletin notes that if the federal HHS later requires Colorado to defray additional costs, the DOI will notify the relevant state legislative health committees.

Employers should be aware of the state coverage requirements and contact the carrier for further details.

For additional information, please see:

• Emergency Regulation 25-E-04 Concerning Coverage of COVID-19 Vaccines as a Preventive Service
• Public Health Order 25-01: Access to COVID-19 Vaccines
• Bulletin B-4.155 Concerning Coverage of Biomarker Tests in Health Benefit Plans
• Bulletin No. B-4.154 Concerning Coverage of PANs/PANDAs in Health Benefit Plans