CMS to Relax Medicare Billing Rules to Speed COVID-19 Vaccine Distribution in Nursing Homes

DATE: October 16, 2020

Skilled Nursing News

By Alex Spanko | October 16, 2020

The federal government on Friday announced its intention to relax restrictions around billing Medicare for immunization in nursing homes, with the stated goal of speeding the eventual distribution of a COVID-19 vaccine.

Skilled nursing facilities are typically required to bill Medicare directly for immunizations under the terms of the Social Security Act, even if the vaccines are provided by a third-party firm such as an independent pharmacy.

Citing the ongoing federal coronavirus emergency, the Centers for Medicare & Medicaid Services (CMS) will use “enforcement discretion” to widen the group of providers that can be reimbursed for COVID-19 vaccinations.

“Through the exercise of that discretion, CMS will allow Medicare-enrolled immunizers, including but not limited to pharmacies working with the United States, to bill directly and receive direct reimbursement from the Medicare program for vaccinating Medicare SNF residents,” CMS announced in a Medicare Learning Network announcement.

The news came the same day that the Department of Health and Human Services (HHS) announced a partnership with retail pharmacy giants Walgreens and CVS to distribute vaccines to nursing homes and other congregate care settings across the country at no cost to operators or residents. Walgreens and CVS will bill Medicare, Medicaid, and private payers for the direct administration of the vaccine, federal officials indicated, with Washington already picking up the tab for acquisition and distribution.

The flexibility will last either until the end of the quarter in which the formal federal emergency is suspended, or “so long as CMS determines that there is a public health need for mass COVID-19 vaccinations in congregate care setting,” whichever comes last.

CMS positioned outside immunization providers as vital to facing the “unprecedented challenge” of distributing a COVID-19 vaccine to seniors in the long-term and post-acute setting.

“Unfortunately, many long-term care facilities may not have sufficient capacity to receive, store, and administer vaccines,” CMS noted in the announcement. “And some long-term care facility residents cannot safely leave the facility to receive vaccinations.”

CMS will provide 60 days’ notice of a change to the waived requirements, the agency indicated.

The COVID-19 vaccines currently under development come with unique logistical challenges, including the need for extremely low-temperature storage and management of multiple doses for each recipient.

“You can’t simply send 100 doses to a nursing home [in one] box, that everybody’s been administered the same drug in the same dose. They’re going to require booster shots. That’s going to be specific to the particular kind of vaccine,” Alan Rosenbloom, president and CEO of the Senior Care Pharmacy Coalition, told SNN in September. “There’s a hell of a lot of patient tracking that’s going to have to happen, and employee tracking is going to have to happen.”

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