Wachler & Associates Health Law BlogHHS Announces New Mechanism to Reimburse for COVID-19 Vaccine Administration
The US Department of Health and Human Services (HHS) has announced a new program to pay healthcare providers for COVID-19 vaccine administration to underinsured patients, the COVID-19 Coverage Assistance Fund (CAF). CAF is administered by the Health Resources & Services Administration and functions as a claims reimbursement program. Where vaccine administration to uninsured patients is covered by HRSA’s Uninsured Program, CAF is intended to reimburse providers for vaccine administration to patients who have insurance, but whose health plan either denied or only partially paid the claim for vaccine administration. CAF reimburses for COVID-19 vaccine administration at the national Medicare rate.
To submit claims to CAF, providers must first enroll in the program and attest that they (1) have submitted a claim to the patient’s primary health insurance plan and there is a remaining balance from that health insurance plan that either does not include COVID-19 vaccination as a covered benefit or covers COVID-19 vaccine administration but with cost-sharing; (2) have verified that no other third party payer will reimburse them for COVID-19 vaccine administration fees for that patient encounter, or other patient charges related to that COVID-19 vaccination, including co-pays for vaccine administration, deductibles for vaccine administration, and co-insurance; (3) will accept defined program reimbursement as payment in full; (4) agree not to balance bill the patient; and (5) agree to program terms and conditions and may be subject to post-reimbursement audit review.
COVID-19 vaccine administrations occurring on or after December 14, 2020 are eligible for reimbursement by CAF. CAF will reimburse for COVID-19 vaccine administration at the national Medicare rate, which is as follows:
- For dates of service through March 14, 2021:
- Administration of a single-dose COVID-19 vaccine – $28.39
- Administration of the first dose of a COVID-19 vaccine requiring a series of two or more doses – $16.94
- Administration of the final dose of a COVID-19 vaccine requiring a series of two or more doses – $28.39
- For dates of service on or after March 15, 2021:
- Administration (per dose) of a COVID-19 vaccine – $40.00
Where a patient’s health plan has only partially covered vaccine administration, it is unclear whether CAF will reimburse at the Medicare rate or will reduce its payment based on the amount paid by the health plan. HHS also reminded providers not to bill patients for COVID-19 vaccine administration. Where a provider has received payment from a patient for vaccine administration, it must return it before the provider can bill the claims to CAF.
For over 35 years, Wachler & Associates has represented healthcare providers and suppliers nationwide in a variety of health law matters, and our attorneys can assist providers and suppliers in understanding new developments in COVID-19 regulation. If you or your healthcare entity has any questions pertaining to healthcare compliance, please contact an experienced healthcare attorney at 248-544-0888 or wapc@wachler.com.