IMPORTANT: CDC COVID-19 Vaccination Program Requirements

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Michigan Department of Health and Human Services

This message was sent to COVID-19 Providers, Health Systems, INE, IAP, LHD Health Officers, LHD Medical Directors, PH Imms Leads, MCIR Region Contacts and Imms All Staff. I apologize for any duplications.

Dear Immunization Partners,

Please share the following information with providers in your jurisdiction.

The federal Public Health Emergency (PHE) for COVID-19 expired on May 11, 2023; however, the Center for Disease Control and Prevention (CDC) COVID-19 Vaccination Program Provider Agreement remains in place.  This program requires that all organizations and providers participating in the CDC COVID-19 Vaccination Program:

  • must administer COVID-19 Vaccine at no out-of-pocket cost to the recipient 
  • may not deny anyone vaccination based on the vaccine recipient’s coverage status or network status
  • may not charge an office visit or other fee if COVID-19 vaccination is the sole medical service provided
  • may not require additional medical services to receive COVID-19 vaccination
  • may seek appropriate reimbursement from a program or plan that covers COVID-19 Vaccine administration fees for the vaccine recipient, such as:
    • vaccine recipient’s private insurance company
    • Medicare or Medicaid reimbursement
  • may not seek any reimbursement, including through balance billing, from the vaccine recipient

It is important to adhere to the COVID-19 Vaccination Program Provider Agreement, particularly as it pertains to patient access. CDC wants to ensure that providers in the COVID-19 Vaccination Program are not denying requests or turning away patients from obtaining COVID vaccine under this federal program. The CDC COVID-19 Vaccination Program Provider Agreement requires that healthcare providers abide by the terms of the agreement, which states that COVID-19 vaccines are provided at 100% no cost to the vaccine recipient. COVID-19 vaccination providers cannot charge vaccine recipients for the vaccine, for any administration fees, copays, or coinsurance. COVID-19 vaccination providers cannot deny vaccination to anyone who does not have health coverage, is underinsured, or is out of network.

In addition, COVID-19 vaccination providers cannot charge recipients for an office visit or any other fee if the only service provided is a COVID-19 vaccination. If a vaccine recipient has health coverage, providers may seek appropriate reimbursement from the recipient’s plan or program (e.g., private health insurance, Medicare, Medicaid) for a vaccine administration fee. However, providers cannot bill the recipient for the balance not covered by the recipient’s plan or program. For further information on reimbursement requirements, as well as general information and provider support for the COVID-19 Vaccination Program, please see the CDC COVID-19 Vaccination Program Provider Requirements and Support webpage. For a list of provider frequently asked questions about the COVID-19 Vaccination Program, please see the FAQs About Implementing COVID-19 Vaccination Program in Provider Practices.

The Michigan Department of Health and Human Services (MDHHS) wants to Thank You for your participation in the CDC’s COVID-19 Vaccination Program. MDHHS wants to ensure all people in Michigan who wish to be vaccinated can receive vaccine without barriers, with vaccine provided by the federal government. We truly appreciate your continued efforts in helping vaccine recipients understand the importance of vaccination and that COVID-19 vaccines are safe and effective. If you have any questions, please do not hesitate to contact us at checcimms@michigan.gov.

Your Outreach and Education Team,
Alyssa, Andrea, Dianne, Heidi, Lisa, and Sarah