New CMS Toolkit Provides Updated Information on COVID-19 Vaccinations

With the push to quickly vaccinate as many Americans as possible, new information is coming at pharmacists fast and furious. In fact, the Centers for Medicare and Medicaid Services recently updated their toolkit on administering the vaccines. A summary from the National Association of Community Pharmacists highlights the most important changes. Here are more details.

WASHINGTON, DC – An updated toolkit from the Centers for Medicare and Medicaid Services offers additional guidance on vaccine administration reimbursement and details the review process that can be used by states to adjust vaccine administration reimbursement rates in their plans.

“It is important to note that states are establishing their own prioritization based on the ACIP recommendations,” according to the document. “Therefore, state Medicaid and CHIP agencies should coordinate with their state health departments, as well as a wide range of other public and private sector partners and providers to implement this guidance. In addition, states should develop plans to outreach to populations that are traditionally hard to reach.

The toolkit reiterates that to receive free supplies of the COVID-19 vaccine(s), pharmacies, retail clinics, providers, and any other site of care receiving and administering COVID-19 vaccines must sign an agreement with the U.S. government. Under that agreement, pharmacists and other providers must agree to vaccinate individuals “regardless of whether they have health insurance coverage or what type of coverage they have and are prohibited from balance billing or otherwise charging vaccine recipients.”

The updated information also reminds that, following vaccination, vaccine recipients must be provided with emergency use authorization (EUA) Fact Sheets on the vaccine and vaccination cards.

In the updated information, HHS provides additional information on pediatric vaccine distribution: It points out that the Pfizer-BioNTech COVID-19 vaccine is recommended by the ACIP for those age 16 and older, which means that Medicaid beneficiaries age 16-18 receiving care in long term care facilities, or Medicaid and CHIP beneficiaries volunteering or working in healthcare facilities might be able to immediately receive the Pfizer-BioNTech COVID-19 vaccine in Phase 1a, based on state vaccine distribution prioritization. It adds that distribution of the Pfizer-BioNTech and other EUA approved COVID-19 vaccines for those under age 19 will be through the COVID-19 Vaccination Program, just as for adults.

“To provide vaccine to this age group, a provider will need to be enrolled to be a COVID-19 vaccine provider,” according to the toolkit. “Because vaccine distribution is outside of the VFC program, a provider does not need to be enrolled in the VFC program to administer a COVID-19 vaccine to child eligible for the VFC program (i.e., under age 19). It is expected that a COVID-19 vaccine for younger children will become available in 2021.”

In a summary, the National Community Pharmacists Association explains the most significant updates.

“The CMS’ toolkit update provides additional guidance on vaccine administration reimbursement and details the review process states can utilize to adjust vaccine administration reimbursement rates in their state plan,” the NCPA notes. “The toolkit also provides further clarification on the administration of all EUA approved COVID-10 vaccines and managed care network adequacy considerations and requirements.”

According to the group’s summary, states have significant discretion in determining vaccine administration reimbursement rates and they retain many tools which provide flexibilities in determining these rates. In addition, it notes that all states currently claim Federal Medical Assistance Percentage (FMAP) under the Families First Coronavirus Response Act (FFCRA) section 6008 and must therefore provide coverage for vaccine administration except to those with narrow range of benefit that does not ordinarily include vaccine coverage.

The NCPA summary also includes the following;

  • A Medicare and Medicaid data sharing system (CMS Data Exchange – DEX) and process are available to share the Medicare provider enrollment data with all state Medicaid and Children’s Health Insurance Program (CHIP).
  • The updated toolkit highlights pharmacy’s expanded scope of practice, including ordering and administering of COVID-19 tests and vaccines, and encourages states to work with their pharmacy communities to support patient access efforts.
  • CMS requires that each managed care plan must maintain and monitor a network of appropriate providers supported by written agreements that is sufficient to provide adequate access to all services covered under the managed care contract for all enrollees.
  • States are expected to provide Medicaid coverage for COVID-19 vaccinations ordered and administered by licensed pharmacists, or administered by pharmacy interns and pharmacy technicians, as authorized by the PREP act during the public health emergency.

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