Flu & Pneumococcal Vaccines: Expanded SNF Enforcement Discretion for Certain Pharmacy Billing

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

Effective September 20, 2021, CMS exercised enforcement discretion for Skilled Nursing Facility (SNF) consolidated billing provisions related to flu and pneumococcal vaccines. This allows Medicare-enrolled immunizers, including pharmacies, to bill directly and get direct reimbursement from the Medicare program (including vaccine administration and product), whether these vaccines are administered at the same time (co-administered) with a COVID-19 vaccine or at different times. Visit the SNF: Enforcement Discretion Relating to Certain Pharmacy Billing webpage.  This information/webpage was updated September 27, 2021.

“America is facing an unprecedented challenge. Quickly, safely, and effectively vaccinating our most vulnerable citizens in settings that have accounted for about 30 percent of U.S. COVID-19 deaths is a top-priority. Unfortunately, many long-term care facilities may not have sufficient capacity to receive, store, and administer vaccines. And some long-term care facility residents cannot safely leave the facility to receive vaccinations.

Outside immunizers can help fill that urgent need and provide onsite vaccinations at skilled nursing facilities (“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. However, the Social Security Act requires SNFs to bill for certain services, including vaccine administration, even when SNFs rely on an outside vendor to perform the service. See Social Security Act §§ 1862(a)(18), 1842(b)(6)(E).”

Vaccinations for respiratory illnesses reduce the impact and resulting burdens on the health care system during the COVID-19 PHE.  The CDC recommends that patients in post-acute care facilities get the flu vaccine during the COVID-19 pandemic

“The COVID-19 pandemic has caused healthcare personnel to change how they operate to continue providing essential services to patients. Ensuring immunization services are maintained or reinitiated is essential for protecting individuals and communities from vaccine-preventable diseases and outbreaks and reducing the burden of respiratory illness during the upcoming influenza season.”

The above website is worthy of bookmarking and frequent referencing.  It is a “collection of federal resources designed to guide vaccine planning during the COVID-19 pandemic.”