As a reminder, by July 1, 2026, insurers and employer plan sponsors must comply with applicable reporting and payment obligations under the state’s Vaccine Purchasing Act (VPA). The VPA was enacted in 2015 and imposes surcharges on health insurers and group health plans to fund state projects, including the purchase of vaccines for children in the state. The reporting helps the state assess the quantity of vaccines to purchase, store, and distribute to insured children in the state.
Specifically, insurers and plan sponsors must report to the New Mexico Office of the Superintendent of Insurance (NM OSI) the total number of children who are residents in the state, were enrolled in the plan during any part of the previous year, and were under the age of 19 as of the prior December 31. Reporting through the OSI VPA portal is required even when the total number of reportable lives is zero.
Although NM OSI permits an insurer or TPA to report on behalf of a group health plan, some insurers have indicated they will no longer be filing VPA reports or submitting assessments, particularly for self-insured (including level-funded) plans. Accordingly, employers should reach out to their carrier or TPA soon to determine whether the carrier or TPA will address the VPA requirements for the plan or if the employer, as plan sponsor, must report and pay the assessment by the July 1 deadline. Late filing penalties apply.
For further information regarding the reporting requirements and filing guidance, employers should refer to the VPA OSI website, VPA FAQs, and 2026 VPA User Guide.