As long-term care facilities and other health care providers turn their attention and efforts to COVID-19 vaccination, many have inquired about the ability to use Provider Relief Funding (“Funding”) for vaccine-related costs. The U.S. Department of Health & Human Services (“HHS”) recently released updated Frequently Asked Questions (“FAQs”) on the topic. In summary, Funding can be used to support vaccine-related expenses, such as distribution costs, preparatory costs (such as obtaining refrigerators, personnel costs, and transportation costs), and administration fees. However, consistent with terms and conditions, Funding may only be used for vaccination costs that have not been reimbursed from other sources or that other sources are not obligated to reimburse. For example, Medicare has determined payment rates for COVID-19 vaccine administration: for single-dose vaccines, the payment rate will be $28.39, and for vaccines requiring a series of two doses, the initial dose administration payment rate will be $16.94, and $28.39 for the administration of the final dose in the series. Thus, a provider may not use Funding to cover these same costs for Medicare beneficiaries, but if Medicare reimbursement does not cover the full expense of administering vaccines, and no other source is obligated to reimburse the cost, Funding may be used to cover the remaining associated costs.
The new HHS FAQs specifically provide: