COVID-19 FAQs on Medicare FFS Billing for Vaccine Administration

There are many questions health care providers have concerning COVID-19 vaccine administration. The questions range from who can administer the vaccine to how to bill for it. To find answers to these questions, read along!

Question: How will physicians and other clinicians bill for the COVID-19 monoclonal antibody products and their infusion?

Answer: Physicians and non-physician practitioners shall bill for the COVID-19 monoclonal antibody products and their infusion using the infusion codes with HCPCS codes listed at https://www.cms.gov/medicare/medicare-part-b-drug-average-sales-price/covid-19-vaccines-and-monoclonal-antibodies.

Physicians and other clinicians shall report COVID-19 monoclonal antibody products and their infusion with diagnosis code Z23.

Question: How will physicians and non-physician practitioners bill for COVID-19 monoclonal antibody or COVID-19 immunization vaccine products obtained for free?

Answer: If the COVID-19 monoclonal antibody or COVID-19 vaccine doses are provided by the government or any other entity without charge, physicians and non-physician practitioners should only bill for the administration of the product. When the product is provided for free, health care providers should not include the COVID-19 monoclonal antibody codes or COVID-19 immunization vaccine codes on the claim. However, CMS recognizes that, even when a product is provided for free, many provider billing systems require a charge to be submitted. In such a situation, physicians and non-physician practitioners can bill the monoclonal antibody or COVID-19 immunization vaccine with a token charge of $0.01 (one penny).

Question: Will Medicare require an order from a physician or non-physician practitioner for a COVID-19 immunization vaccine once they are available?

Answer: No, Medicare will not require an order for COVID-19 immunization vaccines. Thus, a beneficiary can receive the COVID-19 immunization vaccine upon request without a physician’s order and physician supervision.

Question: Will Medicare require an order from a physician or non-physician practitioner for a COVID-19 monoclonal antibody infusion?

Answer: Yes, Medicare will require an order for COVID-19 monoclonal antibody infusions. The use of the drug or biological must be safe and effective, as well as reasonable and necessary. Drugs or biological approved for marketing by the Food and Drug Administration (FDA) are considered safe and effective for purposes of this requirement when used for indications specified on the labeling. Therefore, the program may pay for the use of an FDA-approved drug or biological if:

•        it was administered on or after the date of the FDA’s approval;

•        it is reasonable and necessary for the individual patient; and

•        all other applicable coverage requirements are met.

Question: Who can administer the COVID-19 vaccine to Medicare beneficiaries?

Answer: Any individual who is authorized under applicable state scope of practice and licensure requirements may administer vaccines to Medicare beneficiaries. The list of health care provider types eligible to enroll and bill Medicare for the COVID-19 vaccination is available in the provider toolkit, which can be accessed from this website: https://www.cms.gov/medicare/covid-19/enrollment-administering-covid-19-vaccine-shots.

Source: https://www.cms.gov/files/document/03092020-covid-19-faqs-508.pdf