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ACP State Chapter Action Plan on COVID-19 Vaccines

ACP Chapter Action Tool Kit

Prepared by ACP’s Division of Governmental Affairs and Public Policy

January 15, 2021

Why Is A Chapter Action Plan Necessary?

State officials are taking the lead on vaccine distribution planning. As a result, each state decides when populations will be vaccinated, but not all states follow the recommendations of the CDC’s Advisory Committee on Immunization Practices (ACIP). ACP chapters can advocate to make sure frontline physicians, including community-based primary care physicians, are able to get vaccinated as soon as possible. 

Additionally, many patients will be getting vaccinated by non-physician vaccinators, such as pharmacists and clinicians working in retail health clinics. ACP chapters can work with stakeholders to facilitate communication and collaboration among primary care teams and community-based non-physician vaccinators as recommended by ACP.


Vaccinating Community-based Primary Care Teams

The Food and Drug Administration granted an Emergency Use Authorization for two COVID-19 vaccines in 2020. ACP emphasizes that medical indication should govern health care prioritization decisions and recommends that vaccines be initially allocated to high-risk health care workers in direct patient care. ACIP has made similar recommendations.

According to the Kaiser Family Foundation, the vaccine distribution strategies of all states and the District of Columbia place health care personnel in the highest priority group. A January 2021 survey shows 9 in 10 primary care clinicians intend to get vaccinated. However, reports from ACP members and the press have noted that in some areas, community-based primary care physicians are having difficulty getting vaccinated, despite being frontline, high-risk health care professionals. In many areas, hospital and health system-based health care personnel, whether they are front-line physicians at high-risk of COVID-19 exposure or not, are being vaccinated before community-based primary care physicians.

Notably, ACIP recommends “public health authorities and health care systems should work together to ensure COVID-19 vaccine access to health care personnel who are not affiliated with hospitals.” ACP urges chapters to contact their state governor and relevant stakeholders to support efforts to communicate and coordinate with community-based primary care physicians and their teams so that they are vaccinated as soon as possible.

Vaccine Administration, Distribution, and Payment

ACP recommends an “all-hands-on-deck” approach to COVID-19 vaccine administration, utilizing trained, certified community-based vaccinators in coordination with the patient’s primary care team. In many areas, non-physician clinicians, such as pharmacists and retail health clinic personnel, will administer vaccines, educate patients about vaccine safety, and perform other duties. However, community-based vaccinators do not always coordinate care with the patient’s primary team, which could result in duplicative care or other problems. In the context of the COVID-19 pandemic, ACP recommends non-physician vaccinators, including pharmacists and clinicians working in retail health clinics, must communicate, coordinate, and collaborate with the patient’s primary care team, inform the patient of the need for post-vaccine follow-up care, and provide a referral to a primary care physician if the patient does not have one.

The CDC’s COVID-19 Vaccination Program requires participating organizations to record vaccine information in the patient’s record and report to the relevant public health authority.

In many jurisdictions, vaccinators will use the Immunization Information Systems (IIS) or other reporting system that collects vaccination records from physician offices, hospitals, health clinics, pharmacies and other settings. Physicians can check the IIS to determine their patient’s vaccination history.

The CDC’s COVID-19 Vaccination Program also ensures that patients can get the vaccine at no cost. As a result, vaccinators must agree to vaccinate patients regardless of their ability to pay and cannot seek reimbursement or balance billing the patient. Payers are responsible for reimbursing vaccinators for administering the vaccine. Private and public payers (including Medicaid) should inform care teams of all billing, coding, and other information necessary to obtain prompt reimbursement for administering the vaccine and providing related counseling and follow-up care to patients. ACP supports requirements that COVID-19 vaccine be provided at no cost to all patients, regardless of coverage status.


ACP Chapters should contact their state’s governor and recommend:

  • Community-based primary care physicians and their team members are included in the first wave of vaccinations and receive clear information on when and where they can be vaccinated.
  • Stakeholders widely distribute to vaccinators all vaccine-related educational and outreach materials, quality protocols, storage and handing information, documentation, and other requirements specific to COVID-19 vaccines authorized under an Emergency Use Authorization. A sample letter that chapters can customize is available.