On October 16, 2020, CMS announced that it will allow Medicare-enrolled immunizers, including, but not limited to, U.S. pharmacies, to bill and receive direct reimbursement from the Medicare program for vaccinating Medicare beneficiaries residing in skilled nursing facilities (SNFs). In absence of the exercise of such discretion, the Social Security Act’s Consolidated Billing Provisions would have required SNFs to bill for COVID-19 vaccine administration even when SNFs rely on an outside vendor to perform the service. CMS stated that the U.S. is facing an unprecedented challenge in meeting the urgent need to vaccinate the most vulnerable citizens in SNFs where about 30 percent of U.S. COVID-19 deaths have occurred. CMS stated, “Outside immunizers can help fill that urgent need and provide onsite vaccinations at SNFs [but] to do so during this global emergency, Medicare-enrolled vaccinators must be able to bill directly and receive direct reimbursement from the Medicare program.”
The ability of immunizers to directly bill and receive direct reimbursement will be in effect until the latter of: (1) the last day of the calendar quarter in which the last day of the emergency period occurs; or (2) so long as CMS determines that there is a public health need for mass COVID-19 vaccinations in congregate care settings.