The initial supply of COVID-19 vaccines will be federally purchased, and there will be no cost to the American people who receive the COVID-19 vaccine. Since healthcare providers will play a pivotal role when the COVID-19 vaccine is available, the Centers for Medicare & Medicaid Services (CMS) has released a toolkit to ensure that providers have the necessary resources for the administration of the vaccine.
Providers who participate in the COVID-19 Vaccination Program must contractually agree to administer the vaccine regardless of the individual’s ability to pay and regardless of their coverage status. People without health insurance or whose insurance does not provide coverage for the vaccine can also receive the vaccine at no cost. The providers administering the vaccine to this population can request reimbursement through the Provider Relief Fund.
The CMS resources are designed to increase the number of providers who can administer the vaccine and ensure adequate reimbursement under Medicare, while making it clear to private insurers and Medicaid programs that it is their responsibility to cover the vaccine at no charge to beneficiaries. In addition, CMS is taking action to increase reimbursement for any new COVID treatments that are approved by the FDA.
The initial toolkit’s primary focus is on coverage of vaccine administration. The toolkit includes information to describe:
- How healthcare providers can enroll in Medicare to bill for administering COVID-19 vaccines when available
- The COVID-19 Vaccine Medicare coding structure
- The Medicare reimbursement strategy for COVID-19 vaccine administration
- How healthcare providers can bill correctly for administering vaccines, including roster and centralized billing
The toolkit will be updated as more information becomes available and can be accessed here.
Compliance Perspective
Issue
There will be many questions regarding the anticipated COVID-19 vaccine, including cost and billing for the vaccine. Now is the time for facility leaders to educate residents and staff about the vaccine, including that it will be administered at no cost. Each facility’s leadership and billing personnel should become familiar with the billing and coding protocols for the anticipated COVID-19 vaccination.
Discussion Points
- Begin to develop policies and procedures to guide the COVID-19 vaccination process, including a procedure for billing and coding of the COVID-19 vaccine that follows the CMS Toolkit guidelines.
- Educate employees that the COVID-19 vaccine will be provided at no cost. Train business office staff about the billing guidelines and coding for the COVID-19 vaccine.
- Develop an audit tool to ensure that all COVID-19 charges are being coded correctly.
