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A summary of presentations from the weekly Summit partner webinars

March 21, 2024 – The latest Summit Summary

Medicare and Tools to Facilitate Adult Immunization – Kristi Martin (CMS) 

Kristi Martin, Chief of Staff, Centers for Medicare (CMS), gave a presentation on Medicare and tools to facilitate adult immunization. 

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Overview 

  • Medicare is made up of four parts: A, B, C, and D 
  • Medicare part D – Inflation Reduction Act (IRA) (CMS fact sheet) 
  • Changes mandated by the IRA took effect January 1, 2023 
  • All part D plans must cover ACIP recommended vaccines for adults without any cost-sharing, including deductible  
  • Includes full cost of vaccines, associated tax, dispensing fee, administration fee 
  • Covers vaccines based on shared clinical decision making, and those for use in limited populations and circumstances 

Medicare Part D Vaccines  

Medicare Part D Vaccines  

  • Part B pays 100% of the Medicare allowed amount for vaccines: pneumococcal, flu, hepatitis B, COVID-19 
  • No enrollee cost-sharing on ingredient cost, associated tax, dispensing fee, or administration fee 
  • January 1, 2024, Medicare began providing anadditional payment amount for administering flu, hepatitis B, and pneumococcal vaccines in the home for some Medicare patients 
  • Providers can give COVID-19, flu, and pneumonia vaccines to people who live in retirement communities 
  • Considered “mass immunizers” 
  • Resource on Part B vaccine administration related to people with Medicare in skilled nursing facilities: Billing Medicare for Respiratory Vaccines 

Medicare and other resources on cms.gov: 

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Questions

Q: Can you comment more on travel vaccines?  

Kristi Martin (CMS): With the new Part D vaccine no cost-sharing benefit, we do get a lot of questions about these travel vaccines. If it’s recommended by ACIP for adults, including a vaccine that may be a travel vaccine, occupational, or outbreak vaccine, if you follow the recommendation for who could get that, and this includes shared decision making, then that vaccine is available for no cost and covered by Part D. 

  

Q: Extending the flexibilities of the COVID Public Health Emergency around pharmacist provision of services, roster billing and other issues:  We understand the CMS has been considering what might still continue. Could you comment on the possibilities of these flexibilities being extended, given CMS research into the legal or regulatory parameters?  

Kristi Martin (CMS): We put out a public health emergency toolkit that’s available online. During the public health emergency, we were able to use a lot of flexibility including enforcement discretion to make sure that people are still being served by the Medicare program and being delivered their services. This was one of the areas where we were using that enforcement discretion. Now that we are no longer in the public health emergency, we are not able to leverage that enforcement discretion any longer. I think it’s something that we’re always looking for feedback on. We constantly feel like we are in a rulemaking phase. We are consistently looking for feedback from individuals on how things are working out and what issues they’re seeing. This would be an area that I would suggest people contact with us on. We talk a lot with our colleagues over at the Office of the Assistant Secretary of Health. We appreciate partnership to help raise some of these issues so that we can keep an eye on what is going on and really think through how we might proceed. 

L.J Tan (Immunize.org): What I’m hearing right on is that you’re keeping an eye on it. It’s not there but there are opportunities depending on what kind of feedback you’re getting. 

Kristi Martin (CMS): In terms of if there’s another public health emergency, we will always look at what those flexibilities are again and whatever we can leverage. Ultimately, it comes down to what is our authority and do we have the authority to make changes? Sometimes when it comes to policy, how a person interprets our authority and having that information shared with us is helpful thinking. I don’t anticipate that we will see those flexibilities come back outside of the public health emergency setting. But we’re constantly trying to think through what policy changes we can make to encourage and support immunizations across the board. We know how important they are for not only individual Medicare beneficiaries but also public health in general.  

 

Q: Medicare Part A vs B in LTC/SNF. During COVID vendors were allowed to give other vaccines to both type of patients, but now are limited to Part B vaccines only. After 3 years of this practice many facilities have changed their workflow and no longer order vaccines themselves. Would love some best practices for how to manage this so we can send vendors in. 

Kristi Martin (CMS): I can’t really speak to the vendor relationship. For Medicare we have the payer relationship with the Medicare providers, and in this case it would be the facility. What I can say is that for Part A, for residents including hospice patients, the facility is the one who will bill the vaccine cost and administration fee on the single claims form or if they choose to, through roster billing for multiple patients at a time. The long-term care facility isn’t allowed to bill directly right now for these Part B vaccinations. In the case of a non-Part A long term state resident, the facility can bill a vaccine cost and administration fee on the single claims form or through a roster billing for multiple patients at a time. The long-term care facility can bill directly for both the vaccine cost and the administration fee in that situation. This is for flu, pneumococcal, and COVID-19. This new resource lays it all out to make it more simply stated. The Medicare payment is confusing, so we understand that having resources in a more simplistic language is helpful for people to have.  

 

Q: How can people in different organizations reach out to Medicare and Medicaid programs? 

Kristi Martin (CMS): CMS has regional offices in all 10 regions, just like the Department of Health and Human Services. Within those regions, we have our office for public and local engagement. Those entities worked very closely with state associations and regional associations, and help to facilitate that conduit between CMS and people who want to engage us at a more local level instead of a national level. John Hammerlin is my colleague that leads those regional directors. I encourage people to contact their CMS regional office and make sure they are well connected. In addition, we have a lot of other opportunities. I cannot say enough about my colleagues in the Provider Communications group; they’re constantly putting out amazing resources. They have the MLN connect newsletter that goes out every Thursday with a lot of resources. Make sure to subscribe to those resources and take advantage of what is on cms.gov. We love hearing from everyone; we think it’s powerful to hear from people that are on the ground doing the work. Encourage people to also reach out to us.   

We often set up round tables so my boss, Dr. Mina Tejamani, can sit down with providers who are seeing Medicare patients every day. There are a lot of ways to work with us and get in touch with us. It’s just a matter of shooting an e-mail and you can connect with Susan Farrall at the Department of Health and Human Services to connect with me and others in CMS. 

 

Q: Was the IRA a surprise to you all at CMS? We were pleasantly surprised that this vaccine coverage issue was included in that December 2022 legislation. How long did it take to promulgate the implementation language and how did you fit that into your otherwise busy regulatory environment? 

Kristi Martin (CMS): Versions of the Inflation Reduction Act were popping around the hill for a couple of years in different pieces. So, I think we were definitely expecting it to happen. We hit the ground running with implementation, partly because we had three provisions that got implemented within the first six months. One was a biosimilar temporary add-on payment in part B to providers. A second was the insulin monthly copay cap for $35 in Part D. The third was the vaccination benefits. To successfully hit that January 1 implementation date, we had to be ready to go. We weren’t surprised; we were anticipating it, hoping it would happen, and hoping Congress would act. When it comes to DC, you don’t have 100% assurance that something will happen. 

  

Q: Are there any new Medicare billing codes for counseling or care coordination that would include vaccine counseling? Or SDOH codes? 

 Answered post-webinar by Kristi Martin (CMS): Z71 (pg 100) – Persons encountering health services for other counseling and medical advice, not elsewhere classified Note: Code Z71.84, Encounter for health counseling related to travel, is to be used for health risk and safety counseling for future travel purposes. Code Z71.85, Encounter for immunization safety counseling, is to be used for counseling of the patient or caregiver regarding the safety of a vaccine. This code should not be used for the provision of general information regarding risks and potential side effects during routine encounters for the administration of vaccines. 

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Additional Resources

Resources:  

Webinars: 

Please send any additional questions additional immunization questions for CMS programs to Susan Farrall at susan.farrall@hhs.gov.  

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Announcements
  • Summit will host two webinars for its Virtual Flu days, May 16 and 23, to help partners plan for the respiratory virus season ahead of August, when the Summit’s in-person meeting will follow the National Immunization Conference (NIC). For information on these webinars and to register for one or BOTH, see: Setting the Stage for 2024–2025 Respiratory Virus Season.  
  • The Summit in person meeting was moved to August to accommodate the National Immunization Conference (NIC), held in Atlanta, GA, on August 12–14. The Summit in person meeting, focusing on adult immunizations, will now be held August 15 (full day) and August 16 (half day).  Registration is being coordinated with the NIC registration and should be available soon.  
  • The Summit workshop developed tools to address challenges in providing multiple adult vaccines along with COVID-19, flu, and RSV vaccines. See the Summit’s Operationalizing Adult Immunizations in the 2023 Fall Season and Beyond Workshop web page for the deliverables. 
  • There is a new zoom link for the 2024 Summit meetings. If you do not have the new link, please contact info@izsummitpartners.org. 
  • If you have agenda items you are interested in sharing with the Summit, please tell us and we can add you to an upcoming call as a speaker or panelist. Contact information: info@izsummitpartners.org 

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