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February 18, 2021

Health Law Daily

Who Can Administer and Bill Medicare for COVID-19 Vaccinations?

This Bulletin is brought to you by the Accreditation, Certification, and Enrollment Affinity Group of AHLA’s Regulation, Accreditation, and Payment Practice Group.
  • February 18, 2021
  • Ashley Dobbin Calkins , Hancock Daniel & Johnson PC

We have all heard public health officials stressing the importance of getting “shots in arms” as quickly as possible to bring the COVID-19 pandemic under control. While vaccine supply has been limited, production and distribution is expected to increase in the coming months. CMS has issued straightforward guidance for providers interested in administering and billing Medicare for COVID-19 vaccinations. In many cases, providers do not need to take any action and are already qualified to administer and bill. For other providers, Medicare has streamlined the qualification process during the Public Health Emergency (PHE).

Already Enrolled in Medicare as a listed institutional or non-institutional provider type?

If you are enrolled in Medicare under a specific list of approved provider types, you may not need to take any action to administer and bill for the COVID-19 vaccination.

Examples of providers who are already enrolled and approved include hospitals, hospital outpatient departments, skilled nursing facilities (Parts A and B), critical access hospitals, end-stage renal disease facilities, home health agencies, hospice, comprehensive outpatient rehabilitation facilities, federally qualified health centers, rural health clinics, Indian health services facilities, physicians, non-physicians, clinic/group practices, pharmacies (Part B), and mass immunizers (roster billing only).

Already enrolled in Medicare but your provider type does not allow you to bill for administering vaccines?

If you are enrolled in Medicare but your provider type does not allow billing for administering vaccines, you must also separately enroll as a provider type (e.g., mass immunizer) that can bill for vaccinations.

Examples of these types of providers include outpatient physical therapists, occupational therapists, speech pathology services, independent clinical laboratories, ambulance service suppliers, independent diagnostic testing facilities, mammography centers, opioid treatment programs, durable medical equipment (DME) suppliers, and pharmacies (enrolled as DME suppliers).

Enrollment can occur over the phone through your MAC-specific enrollment hotline. Note that Medicare billing privileges established through the Medicare Provider Enrollment Hotline are being granted on a provisional basis. When the COVID-19 PHE declaration is lifted, providers and suppliers will be asked to submit a CMS-855 enrollment application to establish full Medicare billing privileges.

Not enrolled as a Medicare provider?

If you are not already enrolled as a Medicare Provider, you must quality and enroll as a mass immunizer or other Medicare Provider type that allows billing for administering vaccines. As noted above, Medicare has made it quick and easy to enroll over the phone by calling your MAC-specific enrollment hotline and providing your Legal Business Name, National Provider Identifier, Tax Identification number, practice location, and state license number (if applicable).

Are you a mass immunizer?

Mass immunizers (e.g., pharmacies) are a provider type qualified to administer and bill Medicare for COVID-19 vaccinations. Mass immunizers can enroll as centralized billers and send claims directly to Novitas. To qualify, you must operate in at least 3 MAC jurisdictions and obtain prior approval from Novitas. Contact Novitas (1-855-247-8428) with the following information:

  • Estimate of how many patients to whom you expect to administer the COVID-19 vaccination
  • Approximate dates of vaccinations
  • List of states for COVID-19 vaccination clinics
  • Type of services you generally deliver other than preventive vaccinations, if any 
  • If you employ nurses who will administer the COVID-19 shot or if you hired them specifically to give these shots
  • Names and addresses of all entities operating under the provider’s application
  • Contact information for the centralized billing program designated contact

For additional details on enrollment and billing for administering the COVID-19 vaccination, please visit:

https://www.cms.gov/medicare/covid-19/enrollment-administering-covid-19-vaccine-shots

https://www.cms.gov/files/document/covid-19-vaccine-enrollment-scenario-1.pdf

https://www.cms.gov/files/document/covid-19-mac-webpages-and-hotlines.pdf