Vaccine Clarification for Hospice Patients in Skilled Nursing Facilities

The Centers for Medicare and Medicaid Services (CMS) recently released a Medicare Billing Guideline for vaccination when an individual is in a skilled nursing facility (SNF). When a resident is in a SNF under Medicare Part A (including a hospice patient), the SNF should be billing Part B for the resident’s flu, pneumococcal, and COVID vaccines. If the resident has Medicare Part D, then the respiratory syncytial virus (RSV) vaccine should be billed to the Part D plan by the SNF. While flu, pneumococcal, and COVID vaccines are not covered by the hospice benefit, hospices can bill for these outside the benefit per Medicare Claims Processing Manual Chapter 11: Processing Hospice Claims, 30.5 – Hospice Claims for Vaccine Services. LeadingAge National received clarification from CMS that the SNF is required to submit the bill for Part A stays. If the hospice administers the vaccine, then the hospice would need to make billing arrangements with the SNF. Regardless of who furnishes the vaccine to the patient, if the patient is in a Part A-covered SNF stay, then the SNF remains the billing entity.

Contact: Amy Nelson, anelson@leadingageny.org, 518-867-8383 ext. 146