CMS Pub. 100-04, ch. 18, § 10.2

A. Edits Not Applicable to Claims for Pneumococcal, Influenza, Hepatitis B or

COVID-19 Vaccines and Administration

The Common Working File (CWF) and shared systems bypass all Medicare Secondary

Payer (MSP) utilization edits in CWF on all claims when the only service provided is

pneumococcal, influenza, hepatitis B or COVID-19 vaccine and/or their administration.

This waiver does not apply when other services, (e.g., office visits), are billed on the

same claim as pneumococcal, influenza, hepatitis B or COVID-19 vaccinations. If the

provider knows, or has reason to believe that a particular group health plan covers

preventive vaccines and their administration, and all other MSP requirements for the

Medicare beneficiary are met, the primary payer must be billed.

First claim development alerts from CWF are not generated for pneumococcal, influenza,

hepatitis B or COVID-19 vaccine. However, first claim development is performed if

other services are submitted along with pneumococcal, influenza, hepatitis B or COVID-

19 vaccines.

See Pub. 100-05, Medicare Secondary Payer Manual, chapters 4 and 5, for

responsibilities for MSP development where applicable.

B Institutional Claims

Chapter 25 of this manual provides general billing instructions that must be followed for

institutional claims.

The following “providers of services” may administer and submit institutional claims to

the A/B MACs (A) for these vaccines:

Hospitals;

Critical Access Hospitals (CAHs);

Skilled Nursing Facilities (SNFs);

Home Health Agencies (HHAs);

Hospices;

Comprehensive Outpatient Rehabilitation Facilities (CORFs);

Indian Health Service (IHS)/Tribally owned and/or operated hospitals and hospital-based

facilities; and

Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), effective

for dates of service on or after July 1, 2025.

Other billing entities that may submit institutional claims are:

Independent Renal Dialysis Facilities (RDFs).

Effective for dates of service on or after July 1, 2025, RHCs and FQHCs shall submit

institutional claims for pneumococcal, influenza, hepatitis B and COVID-19 vaccinations,

with or without a visit/encounter or qualifying visit on the same day. (See §10.2.2.2 of

this chapter for special instructions for independent RHCs and freestanding FQHCs.)

Institutional providers should bill for the vaccines and their administration on the same

bill. Separate bills for vaccines and their administration are not required. The only

exceptions to this rule occur when the vaccine is administered during the course of an

otherwise covered home health visit since the vaccine, or its administration is not

included in the visit charge. (See §10.2.3 of this chapter).

C Professional Claims

Billing for Additional Services

If a physician sees a beneficiary for the sole purpose of administering a Medicare covered

preventive vaccine, they may not routinely bill for an office visit. However, if the

beneficiary actually receives other services constituting an “office visit” level of service,

the physician may bill for a visit in addition to the vaccines and their administration, and

Medicare will pay for the visit in addition to the vaccines and their administration if it is

reasonable and medically necessary.

Nonparticipating Physicians and Suppliers

Nonparticipating physicians and suppliers (including local health facilities) that do not

accept assignment may collect payment from the beneficiary for the administration of the

vaccines, but must submit an unassigned claim on the beneficiary’s behalf. Effective for

claims with dates of service on or after February 1, 2001, per §114 of the Benefits

Improvement and Protection Act of 2000, all drugs and biologicals must be paid based on

mandatory assignment. Therefore, regardless of whether the physician and supplier

usually accept assignment, they must accept assignment for the vaccines, may not collect

any fee up front, and must submit the claim for the beneficiary.

Entities, such as local health facilities, that have never submitted Medicare claims must

obtain a National Provider Identifier (NPI) for Part B billing purposes.

Separate Claims for Vaccines and Their Administration

In situations in which the vaccine and the administration are furnished by two different

entities, the entities should submit separate claims. For example, a supplier (e.g., a

pharmacist) may bill separately for the vaccine, using the Healthcare Common Procedure

Coding System (HCPCS) code for the vaccine, and the physician or supplier (e.g., a

drugstore) who actually administers the vaccine may bill separately for the

administration, using the HCPCS code for the administration. This procedure results in

contractors receiving two claims, one for the vaccine and one for its administration.

For example, when billing for influenza virus vaccine administration only, billers should

list only HCPCS code G0008 in block 24D of the Form CMS-1500. When billing for the

influenza virus vaccine only, billers should list only HCPCS code 90658 in block 24D of

the Form CMS-1500. The same applies for the other Medicare covered preventive

vaccinations.

In situations such as a public health emergency when vaccines are supplied at no charge to providers, entities shall

submit claims for the administration of the vaccine only. For example, a provider or supplier may only submit a

claim for the HCPCS code for the administration of the vaccine. If the billing systems providers and suppliers use

will not allow submission of only the vaccine or only the administration, $.01 should be submitted as the charge for

the service that was not provided.

The contractor shall deny claims for vaccine reimbursement costs when the vaccine has been provided at no charge to

providers and suppliers.