Today, the Trump Administration released a comprehensive plan that includes proactive measures to remove regulatory barriers and ensure coverage and payment for the administration of an eventual COVID-19 vaccine. To ensure broad access to a vaccine (especially for seniors), the Centers for Medicare and Medicaid Services (CMS) released an Interim Final Rule with Comment Period (IFC) that establishes that any vaccine that received Food and Drug Administration (FDA) authorization, will be covered under Medicare as a preventive vaccine at no cost to beneficiaries. The IFC also implements provisions of the CARES Act that ensures immediate coverage of a COVID-19 vaccine by most private health insurance plans without cost sharing from both in and out-of-network providers during the course of the public health emergency (PHE).

CMS also released a set of toolkits for providers, states, and insurers to help the health care system prepare to swiftly administer the vaccine when available. These resources are designed to increase the number of providers that can administer the vaccine and ensure adequate reimbursement for administering the vaccine in Medicare while making private insurers and Medicaid programs aware of their responsibility to cover the vaccine at no charge to beneficiaries.

Additionally, CMS released new Medicare payment rates for COVID-19 vaccine administration. The Medicare payment rates will be $28.39 to administer single-dose vaccines. For a COVID-19 vaccine requiring a series of two or more doses, the initial dose(s) administration payment rate will be $16.94 and $28.39 for the administration of the final dose in the series. These rates will be geographically adjusted and recognize the costs involved in administering the vaccine, including the additional resources involved with required public health reporting, conducting important outreach and patient education, and spending additional time with patients answering any questions they may have about the vaccine. Medicare beneficiaries, those in Original Medicare or enrolled in Medicare Advantage, will be able to get the vaccine at no cost. CMS is encouraging state policymakers and other private insurance agencies to utilize the information on the Medicare reimbursement strategy to develop their vaccine administration payment plan in the Medicaid program, CHIP, the Basic Health Program (BHP), and private plans. Using the Medicare strategy as a model would allow states to match federal efforts in successfully administering the full vaccine to the most vulnerable populations.

The IFC (CMS-9912-IFC) is scheduled to display at the Federal Register as soon as possible with an immediate effective date and a 30-day comment period.

Additional information on this IFC can be found in the fact sheet.

The COVID-19 vaccine resources for providers, health plans, and State Medicaid programs can be found here.

The FAQs on billing for therapeutics can be found here.