Vaccine Administration Under Medicare Part D in 2008
After considering comments on its Draft 2008 Call Letter related to the statutory shift of Part D vaccine administration reimbursement from Part B to Part D in 2008, CMS has finalized its operational guidance on administration fees for Part D vaccines. The guidance addresses how payments for the drug product and fees for vaccine administration will work. The Tax Relief and Health Care Act of 2006 (TRHCA) modified the definition of a Part D drug to include vaccines administered on or after January 1, 2008. Beginning on January 1, 2008, the Part D program will cover vaccine administration costs associated with Part D vaccines. CMS has interpreted this requirement to mean that the Part D vaccine administration costs are a component of the negotiated price for a Part D-covered vaccine, including the vaccine ingredient cost, a dispensing fee (if applicable), and a vaccine administration fee. CMS has stated that Part D vaccines, including the associated administration costs, should be billed on one claim for both in- and out-of-network situations. As a result, if an in-network pharmacy dispenses and administers the vaccine in accordance with State law, the pharmacy would process a single claim to the Part D sponsor and collect from the enrollee any applicable cost-sharing on the vaccine and its administration. Alternatively, if a vaccine is administered out-of-network in a physician's office, the physician would bill the beneficiary for the entire charge. The beneficiary would, in turn, submit a paper claim to the Part D sponsor for reimbursement for the total charge: both the vaccine ingredient cost and the administration fee. If a Part D vaccine has specific storage conditions that would limit physicians' offices from maintaining an inventory for their patients and the physician has a pharmacy dispense and deliver the vaccine for administration, the pharmacy would submit the vaccine ingredient cost and dispensing fee to the Part D sponsor for reimbursement and the physician would charge the beneficiary for the administration. CMS has said that pharmacy delivery services would be covered through contracted reimbursements with Part D plans. Recognizing the challenges with current contracting, APhA continues to work with CMS on the implementation of this guidance.To view the CMS vaccine administration guidance visit the APhA website.
The NC Board of Pharmacy now has a final rule allowing pharmacists to administer vaccinations. NCAP would like to help you expand your practice by offering the following resources for pharmacists interested in obtaining certification to administer vaccinations: