ACP Appeals to CMS to Implement Reimbursement Policies for COVID-19 Vaccine Counseling

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Physicians are spending significant time answering patient questions about the vaccines, helping them navigate the system

March 19, 2021 (ACP) – Physicians are spending hours on the phone each month advising patients about COVID-19 vaccines without payment. The American College of Physicians is lobbying the Centers for Medicare & Medicaid Services (CMS) to change reimbursement policies to reflect the new burdens on doctors.

“Our members are incredibly altruistic and caring, and they always put patients front and center. That's why they do this work,” said Dr. Darilyn Moyer, ACP executive vice president and chief executive officer. “Patients turn to physicians because they trust us, and we want to be there for them. But it's important to be adequately reimbursed, especially as so many primary care practices close their doors or curtail their services.”

Codes do exist for visits in which patients are counseled about vaccines and then receive them. “But if you're not actually putting a shot in the patient's arm,” Moyer said, “you can't bill for that, even though you've spent a fair amount of time on the phone helping patients by answering their questions and helping them navigate the system in order to get vaccinated.”

CMS has provided little guidance on reimbursement for calls about vaccines, but it has informally indicated that a check-in code could be used. Unfortunately, reimbursement for this code is inadequate and not appropriate for the time that physicians are spending counseling patients about vaccines.

“Primary care physicians are being bombarded with these calls,” Moyer said, and at least one state is requiring primary care physicians to fill out medical certification letters for patients who want to get vaccinated. “That's creating even more additional unreimbursed work for practices,” she said.

In a recent meeting, ACP urged CMS to issue formal guidance about how to code these types of conversations. Regular evaluation and management codes – even if provided via telemedicine – cannot be used because there is not a principal diagnosis code.

ACP is asking CMS to pay for a risk-management code for this purpose. This kind of code typically requires an in-person visit, but ACP is asking for an exception during the public health emergency. This would be a CPT code, which other payers could easily adopt. Another option is for CMS to create a special G code just for this purpose, but private payers will not be able to adopt it as easily.

“CMS asked us to follow up with more written information,” Moyer said. “Our staff will let them know where we stand. ACP's message is clear: Our members are always there for patients, and they need to be supported.”

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Back to the March 19, 2021 issue of ACP Advocate