COVID-19 Vaccination Program and Provider Compliance

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

As COVID-19 vaccinations continue to be administered nationwide, OIG reminds vaccine providers and the public that this vaccine is being provided by the Federal Government and must be administered at no cost to recipients. Providers participating in the Centers for Disease Control and Prevention’s (CDC’s) COVID-19 Vaccination Program are obligated to comply with the terms of that program.

Regarding the COVID-19 Vaccination Program, CDC has explained:

The COVID-19 Vaccine Is Provided at 100% No Cost to Recipients.
All organizations and providers participating in the CDC COVID-19 Vaccination Program:

  • must administer COVID-19 Vaccine with no out-of-pocket cost to the recipient;
  • may not deny anyone vaccination based on the vaccine recipient’s coverage status or network status;
  • may not charge an office visit or other fee if COVID-19 vaccination is the sole medical service provided;
  • may not require additional medical services to receive COVID-19 vaccination;
  • may seek appropriate reimbursement from a program or plan that covers COVID-19 Vaccine administration fees for the vaccine recipient, such as:
    • vaccine recipient’s private insurance company
    • Medicare or Medicaid reimbursement
    • HRSA COVID-19 Uninsured Program for non-insured vaccine recipients; and
  • may not seek any reimbursement, including through balance billing, from the vaccine recipient.

OIG is aware of complaints by patients about charges by providers when getting their COVID-19 vaccines. Providers that charge impermissible fees must refund them and ensure that individuals are not charged fees for the COVID-19 vaccine or vaccine administration in the future. Consistent with the CDC Vaccination Program, providers are permitted to bill third-party payers (such as Medicare, Medicaid, the HRSA COVID-19 Uninsured Program, or a private insurer) for an administration fee, in accordance with the payer’s applicable billing rules.

In addition, throughout this pandemic, OIG and its law enforcement partners have investigated a steady stream of allegations of COVID-19-related fraud and abuse. Fraudsters are using telemarketing, text messages, social media platforms, and door-to-door visits to perpetrate scams to steal money and personal information from vulnerable people, exploiting fear and confusion. OIG remains vigilant and committed to holding perpetrators of fraud schemes accountable.

OIG has alerted the public to suspicious activity related to vaccines, including:

  • requests for payment to get a vaccine, including deposits or fees,
  • requests for payment or offers of money to enhance ranking for vaccine eligibility (i.e., getting a better spot in line or on a wait list),
  • offers to sell or ship doses of vaccine for payment,
  • offers to purchase vaccine record cards containing personally identifiable information and offers of money to participate in a vaccine survey.

OIG continues to update its COVID-19 Fraud Alert to warn the public about emerging fraud schemes.

The public and private sectors must work together to ensure that vaccine distribution is conducted with integrity and in accordance with applicable rules.

The Centers for Medicare & Medicaid Services has issued guidance about specific vaccine-related fees and provider charges. (See Medicare & Coronavirus.)

Individuals aware of potential fraud or abuse are encouraged to submit their tips or complaints at tips.hhs.gov or call the OIG Hotline at 1-800-HHS-TIPS (1-800-447-8477). Additional OIG resources are available on our web page at oig.hhs.gov/coronavirus.

Christi A. Grimm
HHS-OIG Principal Deputy Inspector General