May 19, 2020
Demetrios Kouzoukas
Principal Deputy Administrator for Medicare and Director Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244
RE: Adult Vaccine Access Coalition (AVAC) Recommendations for the FY2021 Proposed Rule Medicare Program: Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; etc.
Dear Principal Deputy Administrator for Medicare and Director Kouzoukas:
On behalf of members of the Adult Vaccine Access Coalition (AVAC), we write to offer several recommendations in advance of the Centers for Medicare and Medicaid Services (CMS) 2021 Medicare Program: Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements, etc.
AVAC recommendations:
- CMS should immediately issue guidance to Medicare Administrative Contractors (MACs) to clarify that CY20 payment amounts for HCPCS immunization administration codes G0008-G0010 should be equal to, and not lower than, the applicable CY 2019 payment amounts, consistent with the policy you established in the final CY 2020 Physician Fee Schedule regulation.
- CMS should use the upcoming rulemaking cycle to propose adoption of the RUC-recommended practice expense RVUs for CPT immunization administration codes 90471, 90473, and 90460.
- CMS should reaffirm E/M coding that enables primary care providers to conduct patient immunization status assessments and counseling, particularly for complex patients with chronic conditions.
- During this COVID-19 emergency and the upcoming flu season, CMS should announce an enhanced fee for vaccine administration to ensure providers are able to serve Medicare beneficiaries safely.
AVAC consists of over 55 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. AVAC works towards common legislative and regulatory solutions that will strengthen and enhance access to adult immunization across the health care system. Our priorities and objectives are driven by a consensus process with the goal of enabling the range of stakeholders to have a voice in the effort to improve access and utilization of adult immunizations.
Immunizations are an important public health imperative and ensuring that clinicians are properly reimbursed is key to fostering a sustained environment for this high-value preventive service. Vaccine administration by health care providers at the point of care is an opportunity that needs to encouraged. Studies show that inadequate reimbursement for vaccination administration results in missed immunization opportunities and declines in immunization rates.
AVAC is grateful that the Administration acted to stop a proposed 15 percent reduction in payment for CPT codes for vaccine administration (90471-90474) in the CY2020 physician fee schedule (PFS) rule, which stated, “We recognize that it is in the public interest to ensure appropriate payments to physicians and other practitioners for provision of the immunization administration services that are used to deliver vaccines and plan to review the valuations for these services to ensure appropriate payment.”
However, it has come to our attention that some MACs have implemented the 15 percent reduction in the vaccine administration rate for CY20 while others have maintained the CY19 rate in accordance with the final rule. We are concerned that vaccine administration rates remain at risk of further erosion at a time when we need all clinicians to be practicing at the top of their licensure with respect to immunizing. AVAC strongly encourages CMS to take immediate action to address this ambiguity.
Specifically, CMS must instruct all MACs to maintain the CY19 payment rates as CMS intended and any MAC that implemented the CY20 proposed rate should retroactively implement that higher rate and cover any difference in payment to providers that may have occurred as a result of this error.
As we anticipate a vaccine to prevent COVID-19 in the coming months, it is absolutely imperative that Medicare providers are appropriately reimbursed for vaccine services. During routine immunization activities, providers have a number of important responsibilities, 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. A new vaccine for COVID-19 will require all of these activities on a potentially unprecedented scale.
Vaccine administration fees are a key component for maintaining the personnel and resources needed to carry out immunizations. There is a concern for the upcoming influenza season that the people served by Medicare will continue using the telehealth services and mail order pharmacy that were expanded to protect them from COVID-19. Continued use of these services decreases the immunization opportunities for the most vulnerable patients.
To incentivize the implementation of innovative immunization services during this COVID-19 emergency, healthcare providers should be assured that their additional costs will be compensated. We urge CMS to announce an enhanced fee for vaccine administration to ensure providers are able to offer immunization services to Medicare beneficiaries in environments that are safe for all. This could include innovative options such as drive-by or drive-through vaccinations.
Now more than ever before we must effectively utilize proven health care interventions such as immunization that help older adults and individuals with chronic conditions, such as diabetes and heart and lung diseases, to remain healthy. Studies have shown that vaccine preventable illness drives increased morbidity and mortality in these vulnerable populations. Immediate action by CMS is needed to address the discrepancy in the CY20 vaccine administration rate. Moreover, the 2021 proposed PFS rule should decouple the practice expense RVU for vaccine administration from therapeutic injection (96372) and instead utilize the RUC-recommended direct PE inputs that were reviewed in October 2009 to publish practice expense RVUs for CPT immunization administration codes 90471, 90473, and 90460. We also encourage CMS to preserve E/M codes that reflect the importance of primary care providers in assessing and counseling medically complex patients on recommended immunization services. Undervaluing the role of primary care undermines the ability of providers to offer this important preventive service to their patients, which threatens their overall health and wellbeing.
We appreciate this opportunity to share our perspective with respect to issues that are having an acute impact on Medicare providers. AVAC members are available to further discuss our comments with you. To learn more about the work of AVAC visit www.adultvaccinesnow.org.
Sincerely,
Alliance for Aging Research
American College of Physicians
American Immunization Registry Association (AIRA)
American Pharmacists Association
Asian Pacific Islander American Health Forum
Association of Asian Pacific Community Health Organizations (AAPCHO)
Association of Immunization Managers
Association of State and Territorial Health Officials
BIO
Dynavax
Families Fighting Flu
GSK
Hepatitis B Foundation
Hep B United
Infectious Diseases Society of America (IDSA)
Immunization Action Coalition
Immunization Coalition of Washington DC
Medicago
Merck
National Association of County and City Health Officials (NACCHO)
National Black Nurses Association
National Consumers League
National Foundation for Infectious Diseases (NFID)
National Hispanic Medical Association
Novavax
Pfizer
Sanofi
Seqirus
STCHealth
Takeda Vaccines, Inc.
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family
Cc: Hospital and Ambulatory Policy Group (HAPG) Ann Marshall
Emily Yoder Liane Grayson
Christiane LaBonte