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Legislative and Regulatory Update

Stay up to date on the laws and policies that affect your pharmacy practice. Connect with us: APhAGovernmentAffairsTeam@aphanet.org.

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James Keagy

CDC expects pharmacists to administer COVID-19 shots for free to the uninsured

Despite the lack of reimbursement under HRSA’s COVID-19 Uninsured Program, CDC has released a new FAQ for participants in the Federal Retail Pharmacy Program stating their expectation that participating providers will continue to administer COVID-19 vaccines to the uninsured at no cost.

CDC states it will consider taking any and all appropriate measures, including the possibility of rescinding the CDC provider agreement for any pharmacist

  • Administering COVID-19 Vaccine at any out-of-pocket cost to the recipient
  • Denying anyone vaccination, or differentially reducing appointment access, based on the vaccine recipient’s coverage status or network status
  • Charging an office visit or other fee if COVID-19 vaccination is the sole medical service provided
  • Requiring additional medical services to receive COVID-19 vaccination
  • Seeking any reimbursement, including through balance billing, from the vaccine recipient.

CDC’s statement also applies to all pharmacists who signed the CDC COVID-19 Vaccine Provider Agreement (i.e., the one signed by providers receiving vaccines from state health departments), which states that providers may not deny vaccination despite a patient’s inability to pay.

In addition, state health departments have notified that individuals aware of any potential violations of these requirements should report them to the HHS Office of the Inspector General.

CDC’s and state health departments’ current statements are certain to discourage providers from staying in the CDC COVID-19 Vaccination Program. As stated above, we are continuing our efforts to work with the CDC to update the COVID-19 Vaccine Provider Agreement and with Congress to provide the funding necessary to ensure uninsured patients’ access to COVID-19 vaccinations without incurring a financial hardship to providers.

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