January 22, 2021 

Dear Director Blackford: 

On behalf of members of the Adult Vaccine Access Coalition (AVAC), we write respectfully to request that CMS provide clarifying instruction to the MACs, following the Physician Fee Schedule Update of January 7, 2021, that payment amounts set in the final CY21 MPFS rule for immunization administration services described by HCPCS codes G0008 (Administration of influenza virus vaccine), G0009 (Administration of pneumococcal vaccine), and G0010 (Administration of hepatitis b vaccine) should be increased by 3.75% pursuant to the Consolidated Appropriations Act, 2021 (P.L. 116-260) along with all other CY 2021 MPFS payment rates. 

AVAC consists of over 60 organizational leaders in health and public health that are committed to addressing the range of barriers to adult immunization and to raising awareness of the importance of adult immunization. Our organization believes that ensuring that clinicians are properly reimbursed is key to fostering a sustained environment for high-value immunizations. We fully agree with CMS that vaccination services are vital for the health of Medicare beneficiaries, particularly during the ongoing COVID–19 pandemic where health systems are stretched thin, and we believe the MACs, providers, and beneficiaries would benefit from clarification of this supportive payment policy for 2021. 

Administering vaccines comes with a number of important responsibilities for providers, including staff training, ordering and tracking vaccine inventory and ancillary supplies for vaccine administration, proper handling, storage and reporting for each vaccine administered, as well as counseling and educating patients and caregivers. Inadequate reimbursement for vaccination administration discourages providers from proactively offering immunizations, and results in missed immunization opportunities and declines in immunization rates. Routine immunizations for Medicare beneficiaries during the ongoing Covid-19 pandemic will require all of these activities on an unprecedented scale all while having to implement new safety measures while vaccinating. 

Thank you for your consideration to provide clarifying instruction. We also look forward to working with you and other stakeholders to develop additional information to establish appropriate payment for these services on a long-term basis. Please be in touch if AVAC can serve as a resource to your office around adult vaccine issues. 

Sincerely, 

American Academy of Family Physicians

American Immunization Registry Association

American Pharmacists Association 

Families Fighting Flu

GSK 

Hepatitis B Foundation

Hep B United 

Immunization Action Coalition

Infectious Diseases Society of America

Kimberly Coffey Foundation

Medicago 

Moderna 

National Association of Nutrition and Aging Services Programs

National Viral Hepatitis Roundtable 

NFID 

Novavax

Sanofi

STChealth LLC 

The Gerontological Society of America

Vaccinate Your Family 

VaxCare 

Cc: Gift Tee, Ryan Howe