Medical Organizations Urge HHS to Consolidate All Vaccines Under Medicare Part B

Many family physicians know all too well that Medicare beneficiaries' access to preventive vaccines covered under Medicare's Part D retail pharmacy benefit has been a complicated process since the Part D benefit was initiated late in 2005.

In an effort to remove the obstacles, the Academy, the AMA and more than 20 other medical specialty organizations are calling on HHS to include all recommended preventive vaccines under Medicare Part B.

In a June 25 letter to HHS Secretary Kathleen Sebelius, the organizations point out that Medicare beneficiaries have ready access to the influenza, pneumococcal and hepatitis B vaccines under Medicare Part B. However, access to vaccines under Part D is "complex and problematic" because Part D is designed as a retail pharmacy benefit.

That means patients usually purchase Part D vaccines in their physician's office -- which is considered an out-of-network provider -- and then file a claim for reimbursement from their Part D plan.

"This creates a significant barrier to access, especially for low-income beneficiaries," says the letter.

Furthermore, according to results from a recent national CDC survey of physicians that looked at physicians' practices with respect to herpes zoster vaccine, patients are skirting the dilemma with a technique known as "brown bagging." These patients purchase the vaccine from an in-network pharmacy and then transport the product to their physicians' office for administration.

The letter points out that the practice is dangerous because many vaccines must be frozen or refrigerated until immediately before use. "It is difficult for the physician to verify the storage chain from the pharmacy to his or her practice," says the letter.

The medical organizations urge Sebelius to act quickly to review the issue and use the authority granted to her by Section 101 of the Medicare Improvements for Patients and Providers Act of 2008, or MIPPA, to include all recommended preventive vaccines within the "additional preventive services" eligible for coverage under Medicare Part B.

"The Part D benefit is now in its third year of operation, and there is no indication that the vaccine issue is remotely close to being resolved," says the letter.

"CMS' actions to consolidate all vaccines under Medicare Part B will promote the interests of Medicare beneficiaries by further advancing Medicare's focus on prevention. We further urge that such consolidation be considered the result of a change in law (under the MIPPA) so that the resulting costs to Medicare Part B are appropriately accounted for in the calculation of the sustainable growth rate going forward," concludes the letter.