The COVID-19 vaccine rollout started out slow. Vaccination appointments remain scarce. Ambulatory practices can play a critical role in ending the pandemic through vaccination. But many practices are struggling to fulfill tracking and billing requirements from their counties, states, and the federal government.
Government entities are using a patchwork of new and existing technologies to distribute and track the COVID-19 vaccine. But they have overlooked EHRs. The COVID-19 vaccine rollout has not taken full advantage of the EHR technology that most practices already have in place. In fact, government rules have made it more difficult for providers to use their EHRs to administer, track, and bill for vaccines. Even though for years, the federal government has pushed EHR adoption through their Meaningful Use and MACRA initiatives.
Here are some ways the COVID-19 vaccine rollout is failing to take advantage of EHRs.
State and County Rules for COVID-19 Vaccines Keep Changing
States and counties have made many adjustments to their vaccine rollout plans. While some adjustments may be necessary to fix problems in vaccination processes, frequent changes make it difficult for practices to stay on top of the rules and requirements. Practices may have to update their EHRs to comply with each change in the documentation, reporting, and COVID vaccine billing requirements. These updates cost you time and money.
Many states have adjusted their vaccine priority lists since December. Changes in eligibility require your practice to update your outreach targets and adjust appointment scheduling. States also have varied and frequently changing rules about eligibility documentation. Your patients may not know what they need to bring to their appointment to prove their vaccine eligibility. Your staff may not know how to document eligibility in your records even when patients bring the correct paperwork. These changing documentation and eligibility requirements slow down vaccine appointments and the vaccination process.
Some states, like Pennsylvania, have restricted the size of practices that can offer vaccines. Such approaches make it harder for patients to know where to go to get their shot. And if they get their shot elsewhere, there is no guarantee that your office will have access to that information.
Rules for COVID-19 Vaccines Don’t Take Existing EHR Systems into Account
The COVID-19 vaccine rollout includes many eligibility tiers that differ across states and localities. Many of these eligibility categories do not align with fields collected in EHRs. For example, your EHR can not help you identify essential workers eligible based on their occupation. This makes it difficult for you to reach out to your patients who may be eligible.
Public health departments, pharmacies, hospitals, and practices are all administering vaccines and by now most should be using HL7 immunization interfaces. These interfaces were requirements of many stages in Meaningful Use and were heavily invested in. However many states and local governments are requiring additional non-standard information, such as Vaccine Priority, to be sent via the HL7 interface. These requirements send EHR vendors scrambling to deploy new versions to multiple clients who then need to upgrade. While these requirements sound great in theory, the reality of a Software Development Life Cycle (SDLC) is simply ignored.
State and local governments are also often requiring practices to update inventory on various immunization registries' proprietary websites with no accommodations for interoperability. Why is this not able to be accomplished via the HL7 interfaces many practices already invested in? This places additional burdens on an already over-taxed healthcare system that must be efficient right now in order to vaccinate patients in record numbers.
Your practice must also report COVID-19 vaccinations and side effects through multiple unrelated systems. The CDC requires you to record all vaccination data in your EHR system within 24 hours of administration. You must also report all vaccinations to relevant public health departments within 72 hours. These public health systems cannot draw data from your EHR system. Instead, you must submit it separately. The FDA system for reporting COVID-19 vaccine side effects is also not connected to EHRs. It is also separate from commonly used systems to report quality data. Finally, COVID-19 vaccine tracking is not taking advantage of existing EHR capabilities like NextGen’s Vaccine Inventory Solution or the NextGen Vaccine Registry Interface.
Billing for the COVID-19 Vaccine Differs from All Other Vaccines
Because the federal government is purchasing COVID-19 vaccines directly, providers only bill for vaccine administration. This differs from other vaccines with the exception of the Vaccines for Children (VFC) Program. For example, Medicare reimburses practices 95 percent of the average wholesale price for the flu vaccine plus administration costs. The Centers for Medicare and Medicaid Services (CMS) recently increased Medicare and Medicaid reimbursement for COVID-19 to better reflect the costs of proper vaccine storage and administration.
However, these vaccine administration codes are different per vaccine manufacturer and dose. Again, this is different from how other vaccine administration codes work. EMR billing was not created to accommodate such intricate vaccine billing requirements. To meet this need, many EHRs would need to patch their systems, and the release of the codes and how to bill did not allow for time for this. Without innovative companies like TempDev who can quickly turn around development, many practices would be relying on their nursing staff to remember the multitude of billing rules required by COVID-19 vaccine administration.
To access vaccines, your practice must sign an agreement with the federal government that requires you to provide vaccinations regardless of insurance status without balance billing. Unlike with other vaccines, you can also bill the Provider Relief Fund when administering vaccines to the uninsured. Within Medicare, you must bill for administering the COVID-19 vaccine through traditional Medicare for Medicare Advantage enrollees.
These rules were designed to make the vaccine available to as many Americans as possible. But they can make it difficult for you to streamline your billing practices. Solutions like the TempDev COVID-19 Vaccine Clinic Template can help you set up standard billing rules for common insurance types. This saves you time when billing for COVID-19 vaccine administration.
EHR Systems Could Help Speed Up the COVID-19 Vaccine Rollout
Most ambulatory care practices in the US have invested in EHR technology with the help of the federal government. Your EHR system can help you streamline workflows and deliver vaccines quickly and effectively. But changing rules can create confusion, errors, and EHR headaches. Consistent rules for vaccine documentation, administration, and reimbursement that align with existing EHR technologies could speed vaccine rollout.
EHR systems, like NextGen, can share data with other providers and health systems. But this data sharing is not automatic. Suppose one of your patients received a first dose of the Pfizer-BioNTech or Moderna vaccine from another provider. In that case, you might not have access to the data you need to confirm the date and manufacturer of their previous dose. This can create administrative hassles for both you and your patients. This is a perfect use case for HL7 immunization bi-directional interfaces that were required as part of Meaningful Use but are not being utilized as intended.
Federal data sharing standards for COVID-19 vaccines, along with consistent patient identifiers, could help resolve these problems. The new information blocking rule should prevent providers and hospitals from refusing to share data. But, more work is needed to ensure interoperability and data sharing tools are used consistently and effectively.
How TempDev Can Help With COVID-19 Vaccine Rollout
TempDev’s NextGen developers and consultants can help you customize your EHR to meet COVID-19 vaccine tracking and billing requirements. TempDev has developed a COVID-19 Vaccine Clinic Template to let you document and bill for COVID-19 vaccines in just a few clicks. If your practice is struggling to administer the COVID-19 vaccine efficiently, TempDev can help.
Call us at 888.Temp.Dev or contact us for help with your COVID-19 vaccine clinic.
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