HRSA issued revised FAQs clarifying that the COVID-19 Uninsured Program (the “HRSA Program”) will reimburse providers for the costs of COVID 19 vaccine administration for uninsured individuals, once a COVID-19 vaccine receives either an Emergency Use Authorization (EUA) or full licensure from the FDA (the program previously covered COVID-19 testing and treatment but not vaccine services). Consistent with HRSA’s prior guidance regarding treatment services, it appears that an individual with public or private health coverage will be deemed “uninsured” for purposes of the HRSA Program if the individual lacks specific coverage for the COVID 19 vaccine. Thus, in addition to supporting access for individuals who are fully uninsured (including undocumented immigrants), the HRSA Program could help to address certain gaps in vaccine coverage. Notably, a vaccine authorized via EUA (as opposed to full licensure) may not be covered by Medicare. As for Medicaid, vaccine coverage is required during the federal Public Health Emergency (PHE), but once the PHE ends, each state may decide for itself whether to cover COVID-19 vaccines for “non-expansion” adult populations, including those who are eligible for Medicaid by virtue of advanced age, disability, or parenthood.

Addressing these coverage gaps will provide crucial support for healthcare providers participating in the COVID-19 vaccine distribution effort. The Administration’s September 16 vaccine planning guidance suggests that, although the federal government will bear the costs of acquiring and distributing COVID 19 vaccines (at least at first), the Administration will not necessarily take on the cost of vaccine administration, especially in cases where such costs are covered by public or private payers. Even so, the participation agreement for the COVID 19 vaccination program requires participating providers to administer the COVID 19 vaccine to any eligible individual regardless of coverage or ability to pay. Although the HRSA Program generally links reimbursement to Medicare rates for testing and treatment services, it is not clear how HRSA will set a fee schedule for vaccine administration, particularly if, with respect to a vaccine authorized via EUA, HRSA Program reimbursement becomes available before Medicare coverage kicks in. Whereas Congress appropriated specific funds to cover testing costs in the HRSA Program, the testing and vaccine administration are paid for using the Provider Relief Fund, of which $27 billion remains unallocated to date.