IAPAC Joins NACHC and 38 Other Organizations in Advocating COVID-19 Vaccine Reimbursement for FQHCs via Medicare and Medicaid

By Dashiell Sears, IAPAC Director of Advocacy and Public Policy

IAPAC has joined the National Association of Community Health Centers (NACHC) and 38 other organizations in urging acting Director Liz Richter of the Centers for Medicare and Medicaid Services (CMS) to implement COVID-19 vaccine reimbursement policies for federally qualified health centers (FQHCs).

The request outlines extenuating challenges related to ensuring timely and effective vaccine distribution specific to COVID-19, including vaccine storage capacity, staffing for longer vaccine site operations, IT needs, cleaning, patient transportation, increased outreach activities to vaccine hesitant communities. Other challenges related to alterations and rentals for temporary vaccine staging sites and other necessities for staff including PPE, and lost revenue for staff redeployment.

Medicare and Medicaid serve the most at-risk populations in highest need of COVID-19 protections. The current reimbursement is $28.39 for single-dose COVID-19 vaccines. For vaccines requiring two doses, the reimbursement is $16.94 for the first dose and $28.39 for the second dose. These reimbursements are scheduled to take 12-18 months for processing and repayment. Additionally, while providing critical services to Medicaid patients, many vaccine-only visits to FQHCs do not trigger a Medicaid bill covered under the Prospective Payment System to providers.

To ensure ongoing operations are funded, IAPAC, NACHC, and 38 other organizations made the following requests to the CMS:

For Medicare:

  • A COVID-19 interim payment based on the Medicare Part B physician payment fee schedule to ensure payments are provided before 2022; and
    100% reimbursement for FQHCs for COVID-19 vaccine administration given the additional costs related to administering the vaccines.

For Medicaid:

  • Require states to cover COVID-19 vaccine administration as mandatory under an increase in repayments under new services or create an alternative payment methodology (APM);
  • Encourage states to propose APMs that adequately cover the increased administrative costs for COVID-19 vaccine distribution;
  • Provide flexibility for COVID-19 vaccine-only visits to trigger a billable visit; and
  • Retroactively reimburse FQHCs for the additional costs of COVID vaccinations should new policies be implemented.

IAPAC supports implementing these proposed policies and joins our partners in calling on the Biden Administration and the CMS to ensure adequate compensation is provided to FQHCs that serve vulnerable communities, including those most at risk of HIV infection and most in need of continuous HIV treatment, as COVID-19 vaccine distribution ramps up in hard-hit states.