5 Things You Need to Know About The Pharmacy Partnership for Long-Term Care Program

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On October 16, 2020, the Centers for Disease Control and Prevention (“CDC”) announced a partnership with the Department of Health and Human Services (“HHS”), the Department of Defense (“DoD”), and pharmacy retailers, CVS and Walgreens, through which COVID-19 vaccines, once available, will be administered to long-term care facility residents and staff nationwide. The Pharmacy Partnership for Long-Term Care Program (the “Program”) is based on a CDC distribution pilot program that began in August in select states and is intended to provide end-to-end coverage of the COVID-19 vaccination process.

Here’s what you need to know about the Program:

  1. Eligibility: Participation is optional but open to all providers serving residents over sixty-five (65) in long-term care (“LTC”) settings including skilled nursing facilities, nursing homes, assisted living facilities, residential care homes, and adult family homes.
  2. Scope & Coverage: All residents and staff of participating LTC providers will be eligible to receive vaccines on-site at the facility in which they reside, including those in most rural areas. Participation in the Program covers the vaccine product, administration of the vaccine, as well as all ancillary supplies, including needles, alcohol prep pads, syringes, surgical masks, face shields, and vaccination cards. However, enrollment does not guarantee the vaccine product, administration, or supplies; it simply identifies your facility as having residents and staff willing to receive the vaccine from CVS or Walgreens when it becomes available and if your facility is eligible under the Advisory Committee on Immunization Practices (“ACIP”) recommendations.
  3. Enrollment: Providers that wish to participate must enroll and enrollment varies by provider type. Nursing homes must enroll through the National Healthcare Safety Network Portal, available here, while assisted living facilities and other congregate settings must enroll through an online REDcap form, available here. During enrollment, providers can choose to partner with either CVS or Walgreens. Questions regarding enrollment can be sent to the CDC at eocevent494@cdc.gov.
  4. Deadline & Timing: Enrollment opened October 19, 2020 and the new, extended deadline expires on November 6, 2020. CVS and Walgreens will begin providing the vaccine within 24-48 hours of the FDA authorization and ACIP recommendation and will continue to administer the vaccine on-site at participating LTC facilities for two months, as the vaccine is anticipated to require two doses and up to three visits per inoculation.
  5. Costs: Neither the provider nor its residents or staff will incur any costs or expenses associated with Program participation or vaccination. CVS/Walgreens will bill Medicare, Medicaid, or the appropriate private insurer for administration of the vaccine. HHS will pay for the cost of the vaccine itself.

In determining whether to enroll in the Program, LTC providers must evaluate a number of factors, including vaccine availability, administrative burden, liability, and its overall financials. Although the Program is not mandatory, CDC Deputy Director for Infectious Diseases, Jay Butler, M.D., has warned that “[t]hose that choose not to participate in the program need to be prepared to have the resources to address all aspects of COVID-19 vaccination through their state health departments or other resources.” Any provider can opt to use its own pharmacy or a third-party pharmacy; however, doing so shifts the burden for vaccine supply and management, including cold chain requirements, storage, handling, administration, and public health reporting requirements, to the provider and/or pharmacy, which will be required to execute a CDC COVID-19 Vaccination Program Provider Agreement. The administering pharmacy – contracted or owned – should receive payment for administration of the vaccine, either through public or private insurance. It seems unlikely, however, that the insurance reimbursement for vaccine administration alone would outweigh the concerns and risks of supplying and managing the vaccine. One potential compromise could be for providers to utilize the Program for the initial COVID-19 vaccination rollout with existing residents/staff and then transition to a preferred pharmacy following the first two months of the Program. No matter your decision on participation, you’ll be in good company: HHS Deputy Chief of Staff for Policy, Paul Mango, has advised that nearly 10,000 providers have enrolled as of last Friday, October 23, leaving tens of thousands yet to enroll.

Stotler Hayes Group is continuously monitoring The Pharmacy Partnership for Long-Term Care Program, as well COVID-19 recommendations and mandates.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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