​DHS COVID-19 PROVIDER GUIDANCE // OMAP​

SARS-CoV-2 Vaccine Administration by Pharmacists

Effective: December 1, 2020; Issued: December 30, 2020

Purpose

The purpose of this bulletin is to inform pharmacies that the Medical Assistance (MA) Program will make payment for the administration of the novel coronavirus (SARS-CoV-2) vaccines to MA Program beneficiaries by licensed pharmacists.

Scope

This bulletin applies to licensed pharmacies enrolled in the MA Program who provide services in the fee-for-service (FFS) delivery system or through the MA managed care organizations (MCOs) in Physical Health HealthChoices and Community HealthChoices. Providers rendering services to MA beneficiaries in the managed care delivery system should address any questions related to vaccine administration billing and payment to the appropriate MCO.

Background/Discussion

The MA Program has historically paid enrolled physicians, certified registered nurse practitioners, certified nurse midwives, outpatient hospital clinics, and independent medical surgical clinics for administration of vaccines to MA beneficiaries but did not pay pharmacies for the administration of vaccines by pharmacists.

Pharmacists who are licensed to practice pharmacy in Pennsylvania may also have the authority to administer injectable medications, biologicals, and vaccines as set forth in Section 9.2 Act 699 of 1961 (Pharmacy Act) and 49 Pa. Code §§ 27.401; 403.

Further, the Secretary of the Department of Health and Human Services issued an amended declaration under the Public Readiness and Emergency Preparedness (PREP) Act, which provided immunity to pharmacists when they administer certain covered countermeasures, which was expanded to include vaccines administered to persons ages 3 years and older, provided that the conditions in the PREP Act and the HHS declarations are met. The amended declaration and HHS Guidance can be found at the following links:

• www.govinfo.gov/content/pkg/FR-2020-08-24/pdf/2020-18542.pdf
• www.hhs.gov/sites/default/files/licensed-pharmacists-and-pharmacy-internsregarding-covid-19-vaccines-immunity.pdf
  

Procedure

Upon emergency use authorization or approval by the Food and Drug Administration, the MA Program in both the FFS and managed care delivery systems will make payment to enrolled pharmacies for the administration of SARS-CoV-2 vaccines by pharmacists to MA beneficiaries in accordance with a licensed pharmacist’s authority to administer vaccines. Pharmacists must comply with all of the requirements governing vaccine administration in the Pharmacy Act and regulations, and the PREP Act and HHS amended declaration, as applicable.

The following procedures apply to the submission of MA FFS claims for the administration of vaccines by pharmacists to MA beneficiaries.

The MA Program does not make direct payments to licensed pharmacists. Pharmacies may submit an 837 Professional (837P) claim to the MA Program for the administration of the vaccines by the pharmacist using the procedure codes as identified below. The billing and rendering provider for the administration fee claim should be the MA-enrolled pharmacy’s National Provider Identifier (NPI). An MA-enrolled prescriber NPI should be submitted in the referring provider field. The MA fee for the administration of vaccines is $10.00.

Pharmacies are to use the following procedure codes for the administration of the COVID-19 vaccines:

Updates to vaccine administration procedure codes can be accessed via the online version of the MA Program Fee Schedule on the Department’s website. 

Pharmacies may also submit claims to the MA Program for payment of the vaccine biologicals for vaccines using the NCPDP standard claim format or the 837P standard claim format using the National Drug Code (NDC) and NDC units for the vaccine that is administered. 

Pharmacies may not bill the MA Program for a vaccine they receive at no cost, including SARS-CoV-2 vaccines purchased by the federal government. 

Resources

• American Medical Association 
• Centers for Disease Control and Prevention 
• PA Department of Health 1-877-PA HEALTH — (1-877-724-3258)
• PA Department of Human Services – Fee-for-Service Pharmacy Services 
• PA Department of Human Services Bulletin Search 
• PA Department of Human Services MA Program Outpatient Fee Schedule