getvaccinated.us
REIMBURSEMENT GUIDE FOR
SKILLED NURSING FACILITY
HEALTH CARE PERSONNEL
FLU AND COVID-19 VACCINATIONS
FREQUENTLY ASKED QUESTIONS ON VACCINE PAYMENT OPTIONS TO
OPTIMIZE SNF STAFF VACCINE UPTAKE
1. Are Influenza and COVID-19 vaccines required for SNF staff?
There are no federal requirements that staff receive these vaccines. However,
there is a regulatory requirement to educate and offer the COVID-19 vaccine
to staff and residents and educate and offer the flu vaccine to residents.
AHCA/NCAL’s #GetVaccinated toolkit contains a summary of the CMS vaccine
regulations.
Some states may have regulations about health care workers (HCW)
receiving these vaccines. For example, some states require either the
influenza vaccine or that the HCW uses a source control mask when around
patients during high activity of influenza in the community. You need to
check with your state health department about any state specific
requirements for vaccination.
2. Are there any quality measures for SNF staff vaccinations?
Yes. The SNF Quality Reporting Program (QRP) creates SNF quality reporting
requirements as mandated by the Improving Medicare Post-Acute Care
Transformation Act of 2014 (IMPACT Act). Currently there are two staff
vaccination quality measures:
SNF QRP Measure #11: COVID-19 Vaccination Coverage among
Health Care Personnel (HCP) (CBE #3636)
• This measure was finalized in the FY 2022 SNF PPS Final Rule, (86 FR
42480 through 42489). Data submission for this measure began
October 1, 2021.
SNF QRP Measure #12: Influenza Vaccination Coverage among
Health Care Personnel (HCP) (CBE #0431)
• This measure was finalized in the FY 2023 SNF PPS Final Rule, (87 FR
47537 through 47544). Data submission for this measure began
October 1, 2022.
getvaccinated.us
REIMBURSEMENT GUIDE FOR
SKILLED NURSING FACILITY
HEALTH CARE PERSONNEL
FLU AND COVID-19 VACCINATIONS
If a SNF fails to submit the required quality data, the SNF will be subject to a
two percentage (2%) point reduction in the Annual Payment Update (APU)
for the applicable performance year.
Data for these measures are submitted via the Centers for Disease Control
and Prevention’s (CDC) National Health Care Safety Network (NHSN).
Information related to the procedures using the CDC NHSN for data
submission for the COVID-19 and Influenza Vaccination Coverage among
HCP measures can be found on the NHSN website. For NHSN
questions: [email protected].
3. Who does CMS consider HCP that the SNF must report the vaccination
status on?
The denominator for the COVID-19 and Influenza SNF QRP measures consists
of HCP who are physically present in the health care facility for at least one
working day:
• During the calendar year for the COVID-19 vaccine (reported weekly - at
least one week per month).
• Between October 1 through March 31 of the following year for the
Influenza vaccine (reported at least once covering the entire flu season).
Denominators are to be calculated separately for the following categories of
HCP as described:
a. Employees (mandatory): This includes all persons receiving a direct
paycheck from the reporting facility (i.e., on the facility’s payroll),
regardless of clinical responsibility or patient contact.
b. Licensed independent practitioners (LIPs) (mandatory): This includes
physicians (MD, DO), advanced practice nurses, and physician
assistants who are affiliated with the reporting facility, but are not
directly employed by it (i.e., they do not receive a paycheck from the
facility), regardless of clinical responsibility or patient contact. Post-
residency fellows are also included in this category if they are not on
the facility’s payroll.
getvaccinated.us
REIMBURSEMENT GUIDE FOR
SKILLED NURSING FACILITY
HEALTH CARE PERSONNEL
FLU AND COVID-19 VACCINATIONS
c. Adult students/trainees and volunteers (mandatory): This includes
medical, nursing, or other health professional students, interns, medical
residents, or volunteers aged 18 or older who are affiliated with the
healthcare facility, but are not directly employed by it (i.e., they do not
receive a paycheck from the facility), regardless of clinical responsibility
or patient contact.
d. Other contract personnel: Contract personnel are defined as persons
providing care, treatment, or services at the facility through a contract
who do not fall into any of the other denominator categories. Please
note this also includes vendors providing care, treatment, or services at
the facility who may or may not be paid through a contract. Reporting
for this category is mandatory for COVID-19 vaccine and is optional for
the Influenza vaccine. Also, the denominator for the COVID-19 measure
excludes HCP with medical contraindications to COVID-19 vaccine.
For more information on Measure Specifications:
• CDC COVID-19 Vaccine Operational Guidance for Long-tern Care
Facilities – July 2023
• CDC Influenza Vaccine Operational Guidance for Long-tern Care
Facilities – January 2023
4. Is the reported SNF staff vaccination data publicly reported?
CMS must make quality data available to the public through the Care
Compare website. To ensure accuracy of this publicly reported data, CMS
gives SNFs the opportunity to review the data before they are posted. Please
see the SNF Quality Reporting Program Help web page for further assistance
5. Is the Federal Government providing any of these the vaccine product
for free?
No. While the U.S. Government (USG) provided many pandemic-related
products for free during the COVID-19 PHE, the U.S. Department of Health
and Human Services (HHS) transitioned the purchase and distribution of the
COVID-19 vaccine to the commercial market in the fall of 2023, similar to how
other vaccines have historically been made available to the public.
getvaccinated.us
REIMBURSEMENT GUIDE FOR
SKILLED NURSING FACILITY
HEALTH CARE PERSONNEL
FLU AND COVID-19 VACCINATIONS
The Centers for Disease Prevention and Control (CDC) established the Bridge
Access Program that will temporarily provide no-cost COVID-19 vaccines to
adults without health insurance and adults with insurance that does not
cover all COVID-19 vaccine costs.
6. How are SNF staff vaccines paid for?
Vaccines for staff are typically covered by their medical insurance at no or
little cost through pharmacies, while uninsured or underinsured staff
vaccines may access vaccine for free through the Bridge Access Program or
by public agencies.
HHS has established a “How to Pay” website that provides details on vaccine
coverage and costs for Private Health Insurance, Military Insurance, Medicare,
and Medicaid. It also contains links to federally funded health centers and the
health departments of each state to learn about options for uninsured and
underinsured individuals.
7. What options do SNF providers have to facilitate staff vaccinations,
especially for COVID-19 and Influenza?
There are multiple pathways:
1. For insured employees –
a. Consider making arrangements with your LTC pharmacy to offer
onsite staff vaccine clinics. The LTC pharmacy may be able to bill
the insurance company or use the Bridge Access Program to
collect payment. This option makes it easier to track HCP
vaccination status.
a. Check with your employee’s insurance company to see if you can
submit a claim to them directly for the vaccine and
administration costs. This option makes it easier to track HCP
vaccination status.
b. Consider incentivizing employees to obtain the vaccination(s) at
their local pharmacy. Develop a process to confirm and record
that the employee obtained the COVID-19 and/or Influenza
vaccine.
getvaccinated.us
REIMBURSEMENT GUIDE FOR
SKILLED NURSING FACILITY
HEALTH CARE PERSONNEL
FLU AND COVID-19 VACCINATIONS
2. For uninsured employees –
a. Consider making arrangements with your LTC pharmacy to offer
onsite staff vaccine clinics. The LTC pharmacy may be able to
obtain reimbursement through the Bridge Access Program.
b. Work with your local state health department or federally funded
health center to help the employee obtain the COVID-19 and/or
Influenza vaccine for free. Develop a process to confirm and
record that the employee obtained the COVID-19 and/or
Influenza vaccine.
3. For non-employees that the facility is required to report HCP
vaccination status on, including licensed independent practitioners,
adult students/trainees and volunteers, and other contract
personnel –
a. Educate these HCPs about the reporting requirement and offer
the HCP information on options for obtaining free or low-cost
vaccines as discussed above for insured or uninsured employees
above. Develop a process to confirm and record that the
employee obtained the COVID-19 and/or Influenza vaccine.
8. Where can I find more information on how to code and bill for the
COVID-19 and Influenza Vaccine if I administer the vaccine to HCP that
have insurance?
Providers should contact the HCP personnel’s insurer for plan-specific billing
guidance.
For reference, CMS has posted updated lists of Medicare Part B codes,
effective dates, and Medicare pricing for Seasonal Flu Vaccines and COVID-19
Vaccines.
9. Are there AHCA/NCAL resources available to educate SNF HCP about
these vaccines?
Providers can refer to the AHCA/NCAL 2023 #GetVaccinated Toolkit.
