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Briefing

California Enacts AB 144: New Standards for Preventive Health Coverage

On September 17, 2025, Governor Gavin Newsom signed AB 144, a health budget trailer bill that revises state requirements and guidance related to the provision of immunizations and the coverage and delivery of various preventive health care services in the state.

As signed into law, AB 144 establishes a path for the state of California to exert more control over the recommended vaccines and preventive services covered under fully insured California health plans under California law. It does so through several steps, as set forth below./p>

• It establishes, as a baseline, the recommendations for preventive services, items, and immunizations as they were recommended by the three federal agencies under the control of the U.S. Department of Health and Human Services—the United States Preventive Services Task Force (USPSTF), the Advisory Committee on Immunization Practices (ACIP), and the Health Resources and Services Administration (HRSA)—up until January 1, 2025.
• It authorizes the California Department of Public Health (CDPH) to modify or supplement the baseline federal recommendations, taking into consideration guidance and recommendations from additional medical and scientific organizations, including, but not limited to, the American Academy of Pediatrics (AAP), the American College of Obstetricians and Gynecologists (ACOG), and the American Academy of Family Physicians (AAFP).
• It authorizes CDPH to incorporate subsequent evidence-based recommendations from the three federal agencies to the extent the department determines them to promote public health.
• It requires CDPH to publish the recommendations of immunizations, items, and services, and publish any updates, modifications, or supplements adopted, which become effective upon publication.
• It updates related provisions for health care benefit coverage, professional and occupational licensing, and school immunization notification statutes to reflect the implementation of state immunization guidelines.
• It extends liability protection for any injury caused by an act or omission in prescribing, dispensing, ordering, furnishing, or in the administration of vaccines or other immunizing agents if required by state law or administered in accordance with guidance from CDPH according to its baseline recommendations, until January 1, 2030.

Essentially, AB 144 freezes in place, for California health plans, the federal vaccine and preventive service recommendations that were in effect prior to Secretary of Health and Human Services (HHS) Robert F. Kennedy, Jr. taking the helm at HHS. It simultaneously authorizes California regulators to supplement and modify those recommendations for the purposes of state and federal preventive coverage mandates.

IMPACT ON GROUP HEALTH PLANS

AB 144 makes the following provisions with regard to the coverage of preventive services under fully insured plans in California.

It will require coverage without cost-sharing under any group or individual non-grandfathered health plan, of the following.

• Evidence-based items or services that had, in effect on January 1, 2025, a rating of “A” or “B” in the recommendations of the USPTF;
• Immunizations that had, in effect on January 1, 2025, a recommendation from ACIP;
• With respect to infants, children, and adolescents, evidence-informed preventive care and screenings provided in the comprehensive guidelines, as periodically updated, supported by the United States Health Resources and Services Administration, as of January 1, 2025;
• With respect to women, those additional preventive care and screenings as provided for in comprehensive guidelines supported by HRSA as of January 1, 2025.

It will also require coverage without cost-sharing, whether delivered in or out of network, of the following.

• Immunizations for COVID-19 or any other disease for which the Governor has declared a public health emergency, if those immunizations had in effect a recommendation from ACIP as of January 1, 2025;
• Immunizations for COVID-19 or any other disease for which the Governor has declared a public health emergency, if those immunizations had in effect a recommendation from ACIP as of January 1, 2025;

Under the statute, all of these required items of coverage will be subject to update by the CHPH. This will mean that there may be one set of items that require coverage without cost-sharing for insureds in California and a different set in the rest of the U.S. This legislation also raises the possibility that, as other states’ lawmakers object to changes made by federal health regulators, there will be different rules in multiple states for fully insured plans.

Keenan is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Clients are advised to consult with their own attorney for a determination of their legal rights, responsibilities, and liabilities, including the interpretation of any statute or regulation, or its application to the clients’ business activities.