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Summarized billing recommendations for 2009 H1N1 vaccine

Organizations provide guidance to aid pharmacists in billing for 2009 H1N1.

Public payers

CMS: Fee-for-service policies, procedures for providers in H1N1 pandemic

In late August, CMS issued information on Medicare fee-for-service policies and procedures in an H1N1 flu pandemic or other public health emergency or disaster. The 22-page document addresses issues related to H1N1 vaccination, flexibilities available in an emergency or disaster, waivers of certain Medicare requirements in a declared emergency or disaster, and payment polices and billing procedures for various types of health care services and providers.

Private payers

Pharmacists may bill for H1N1 vaccine administration to private payers in three ways: (1) through the pharmacy system, (2) via roster bill, or (3) via cash receipt. The mechanism used depends on individual plans. Pharmacies will need to contact plan administrators to determine the appropriate process to use.

(1) Pharmacies with existing relations with plans to bill via the pharmacy claim system or agreement by plan to use this system: Billing consistency recommendations from NCPDP

A task group of the National Council for Prescription Drug Programs (NCPDP) recently recommended that, when billing for a vaccine (e.g., 2009 H1N1) as part of a drug benefit, the same method should be used as that defined for Medicare Part D vaccine administration billing. Therefore, the pharmacy should submit the following fields:

  • Ingredient Cost Submitted (4Ø9-D9) (contains ingredient cost for vaccine, which may be zero for a government-supplied product)
  • Dispensing Fee Submitted (412-DC) (zero for H1N1 claims)
  • Incentive Amount Submitted (438-E3) in the Pricing segment 
(contains administration fee)
  • Gross Amount Due (43Ø-DU) (contains summation of the preceding three fields)
  • DUR/PPS Segment (contains DUR/PPS Code Counter [473-7E] of 1 and Professional Service Fee Submitted [44Ø-E5] with a value of MA [medication administered])

Then, the payer responds with the following fields:

  • Ingredient Cost Paid (5Ø6-F6)
  • Dispensing Fee Paid (5Ø7-F7)
  • Incentive Amount Paid (521-FL)

More information is available in an NCPDP document titled Version 5 Editorial on the NCPDP website.

Also, when rejecting the claim for a vaccine that is not part of a drug benefit, NCPDP recommends that the payer use Reject Code (511-FB) of "7Ø" (Product/Service Not Covered), along with any additional messaging that the plan might know to help the provider determine a follow-up course of action.

(2) Pharmacies billing through medical claims or without preexisting relationship with plan: Roster billing for H1N1 vaccine administration

America’s Health Insurance Plans (AHIP), working with its member plans, the American Pharmacists Association, the National Association of Chain Drug Stores, the National Community Pharmacists Association, the National Association of State Pharmacy Association Executives, pharmacy providers, and other stakeholders, developed a roster bill format in Excel that will be useful for pharmacies and health plans when billing for H1N1 vaccine administration.

The Excel spreadsheet is an H1N1-specific roster billing model that pharmacies and plans should consider using. It attempts to balance the traditional medical claims submission requirements from the health plans with the intake and billing requirements from the pharmacy environment. However, the spreadsheet model is not an intake tool for pharmacies. The expectation is that pharmacies, through standard electronic (and possibly manual) processes, will transfer patient-acquired data elements into the roster bill.

Additional information is available in a previous Ask the Expert article published at APhA’s Pharmacist Immunization Center.

(3) Patients paying cash and submitting claim for reimbursement to plan

HHS Secretary Sebelius has requested that all parties involved “decrease the barriers to vaccination and minimize the administrative complexity of providing access and financing for the administration of this vaccine.” Cash payment for the administration of this public health pandemic vaccine is a potential barrier to vaccination and may place a burden on those seeking this important service. Providers and payers are encouraged to consider billing approaches that reduce the burden on patients.

If pharmacies elect to charge insured patients up-front for administration of the H1N1 vaccine, pharmacies should provide their customers with a receipt that includes the following information:

  • Provider name
  • Provider address, city, state, ZIP Code
  • Provider NPI
  • Provider Tax ID
  • Diagnosis code
  • Vaccine code
  • Administration code
  • Date of service
  • Charge amount
  • Amount patient paid
  • Patient name
  • Medical benefits ID member number and group number
  • Patient date of birth

Patients can submit for reimbursement through their health plan’s established methods and may also need to submit a form with information not captured on the pharmacy receipt. Pharmacies can assist patients with completion of their claim form, if needed.

Web links

Related resources on pharmacist.com

Resource

Joe Sheffer (jsheffer@aphanet.org)
Posted October 22, 2009