Q: My Medical director wants our practice to bill the employee’s insurance for the cost of the hepatitis B virus (HBV) vaccination. I disagree. What do you think?
A: Your instinct is correct. Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens  states: “The employer may not permit the employee to use his or her healthcare insurance to pay for the series unless the employer pays all of the cost of the health insurance and unless there is no cost to the employee in the form of deductibles, co-payments, or other expenses.”
The document explains that partial employee contribution to insurance could penalize the worker in the form of higher insurance premiums that violate the “no cost to the employee” language of the bloodborne pathogens standard. The same reasoning applies to using a spouse’s or family member’s insurance.
Last year the average initial fine for this violation (1910.1030([f][ii][A]) was $1,250.