The Centers for Medicare & Medicaid Services (CMS) has released a fourth COVID-19-focused interim final rule with comment period (IFC) that covers a number of issues, including the reimbursement rates for pharmacist-provided COVID-19 vaccinations and information on outpatient billing for monoclonal antibody treatment if and when it is authorized by the Food and Drug Administration. CMS also released three toolkits addressing the administration of vaccines for Medicaid agencies, private insurers, and providers. Additionally, the IFC details coverage for COVID-19 vaccination, and implements provisions of the Coronavirus Aid, Relief, and Economic Security (CARES) Act that provide Medicare, Medicaid, and private insurance coverage without patient cost-sharing.
- COVID-19 Vaccination Reimbursement: Payment for COVID-19 vaccinations vary based on whether the vaccine is single- or multi-dose. Medicare will reimburse the administration of a single-dose vaccine at $28.39. For multi-dose vaccines, the administration of the first dose is reimbursed at $16.94, and the final shot in the series is reimbursed at $28.39. CMS stated that the rates will be geographically adjusted and “recognize the costs involved in administering the vaccine, including the additional resources involved with required public health reporting, conducting important outreach and patient education, and spending additional time with patients answering any questions they may have about the vaccine.”
CMS also noted some process improvements for vaccinations, including an expedited 24-hour process for enrolling new providers as mass immunizers. CMS will also continue to share information on provider enrollment with states to mitigate any barriers to provider engagement.
- Monoclonal Antibody Reimbursement: While the FDA has not yet released an Emergency Use Authorization (EUA) for COVID-19 monoclonal antibody treatment, the IFC provides information to help providers prepare for its availability. Specifically, the IFC states that to incentivize the use of new treatments, drugs and biologicals approved or authorized (i.e., under an EUA) for COVID-19 cannot be bundled into other services and will instead be separately payable for the duration of the public health emergency.
ASHP is in the process of reviewing the full IFC and will release an issue brief in the coming days. We encourage members to send questions to Jillanne Schulte Wall, ASHP senior director for health and regulatory policy.