October 19th Newsletter - Sachs Policy Group

Governor Cuomo Announces Statewide Vaccine Administration Program

On October 18^th, Governor Cuomo held a press conference during which he announced details of New York State’s COVID-19 Vaccine Administration Program. While the federal government will distribute any approved vaccine at a national level, New York will have a statewide vaccination plan that all local governments will participate in, which is outlined in this draft plan. The plan is subject to change depending on future details expected from the federal government.

The draft plan includes a prioritization matrix and phased approach for vaccine distribution based on population risk, COVID-19 prevalence in a geographic area, and whether individuals are health care personnel or other essential workers. The draft plan also includes measures to ensure vaccine safety and effectiveness, a process for efficient vaccine distribution and delivery, proposed public education and community outreach campaigns, and details on a Vaccine Central Command Center that will manage the entire program.

The Governor also announced that New York State is building a network of facilities for vaccine administration, including:

Hospitals and long-term care facilities
Urgent care clinics, community health centers, rural health clinics
Primary care provider physician offices
Pharmacies
Local Health department sites
Schools and other congregate facilities
Mobile vaccination units
Mass vaccination sites (gymnasiums, convention centers, etc.)

The Governor’s press release is available here. The draft Vaccination Administration Program plan is availablehere.

HHS Announces Partnership with CVS and Walgreens to Prepare LTC Facilities for COVID-19 Vaccine Administration

On October 16^th, the Department of Health and Human Services (HHS) and the Department of Defense (DoD) announced that the agencies had reached agreements with CVS and Walgreens to provide and administer a COVID-19 vaccine, when approved and available, to residents of long-term care facilities (LTCFs) nationwide with no out-of-pocket costs. The “Pharmacy Partnership for Long-Term Care Program” will be available for residents in all long-term care settings, including skilled nursing facilities (SNFs), nursing homes, assisted living facilities, residential care homes, and adult family homes. Starting today (October 19^th), LTCFs may opt into this program and choose which pharmacy partner they prefer. Nursing homes will use the National Healthcare Safety Network to sign up. When a vaccine becomes available, CVS and Walgreens will coordinate the operation of on-site clinic dates directly with each facility.

CMS Waives Requirement for SNFs to Bill For Vaccine Administration

On October 16^th, the Centers for Medicare and Medicaid Services (CMS) released a letter informing that the agency will exercise enforcement discretion with respect to Social Security Act §§ 1862(a)(18), 1842(b)(6)(E), which requires SNFs to bill for certain services, including vaccine administration, even when SNFs rely on an outside vendor to perform the service. To fulfill the public need for mass COVID-19 vaccine administration, when available, CMS will allow Medicare-enrolled immunizers to bill directly and receive direct reimbursement from the Medicare program for vaccinating Medicare SNF residents.

The letter is available here.

CMS Reduces Medicare Reimbursement for High-Throughput COVID-19 Testing Not Completed Within Two Days

On October 15^th, CMS announced that, starting January 1, 2021, Medicare will reduce the fee-for-service (FFS) payment for high-throughput COVID-19 testing that is not completed within two days from $100 to $75. CMS is implementing this by reducing the base amount for high-throughput tests (code U0004) to $75 and instituting an add-on payment (code U0005) for such tests that are completed within two days.

The announcement is available here.

Updated Guidance Documents

The following New York State guidance documents have been recently released or revised: