SNFs: COVID-19 Enforcement Discretion for Pharmacy Billing Ended June 30th

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

For flu, pneumococcal, and COVID-19 vaccines furnished on or after July 1, 2023, to patients in a Medicare Part A-covered skilled nursing facility (SNF) stay, immunizers can no longer bill Medicare directly. Typical SNF consolidated billing regulations are in place, which require SNFs to bill for all services furnished to patients in a Medicare-covered SNF stay, including vaccines. Third-party suppliers furnishing these vaccines under arrangement with the SNF must seek payment from the SNF for their services. Immunizers may still bill Medicare directly for vaccines furnished before July 1, 2023.

During the COVID-19 public health emergency, outside immunizers helped fill the need to provide onsite vaccinations at SNFs. This enforcement discretion related to certain pharmacy billing ended June 30, 2023