More Changes! VFC Program Recommendations and Requirements

Transcription

1 More Changes! VFC Program Maribel Chavez-Torres, MPH Immunization Program Director City of Chicago Mayor Rahm Emanuel Chicago Department of Public Health Commissioner Bechara Choucair, M.D.

2 VFC Eligibility Categories Children through 18 years of age who meet one of the following criteria is eligible to receive VFC vaccine: Medicaid-eligible: a child enrolled in Medicaid or Managed Care Medicaid program Uninsured: a child who has no health insurance coverage or self pay American Indian/Alaskan Native: as defined by the Indian Health Care Improvement Act (25 U.S.C. 1603) Underinsured only at FQHCs 1. A child who has health insurance, but the coverage does not include vaccines, or 2. A child whose insurance does not cover all ACIP recommended (child would be eligible to receive vaccines not covered by insurance)

3 VFC Eligibility Screening Screening for VFC eligibility must occur with ALL clinic patients 0-18 years of age Form must be completed at each immunization visit Documentation of VFC eligibility includes the following elements: - Date of screening - Whether the patient is VFC eligible or not VFC eligible - If patient is VFC eligible record appropriate category Form can be completed by the child s parent, guardian, or legal representative, or by a health care provider. Verification of responses is not required. Documented in the patient s permanent medical record (paper-based or electronic medical record) at each immunization encounter Screening form must be kept in the patient s medical record for (3) years

4 Chicago VFC Program Vaccine Eligibility Reference Table VFC Vaccines Private Health Centers (non-fqhc, non-public) Federally Qualified Health Centers VFC Eligibility Categories VFC Eligibility Categories Medicaid Uninsured Under- Medicaid 1 Uninsured Under- (Self-Pay) Insured (Self-Pay) Insured 2 Am. Indian Alaskan Native HMO/Private Full Coverage Health Insurance Am. Indian Alaskan Native HMO/Private Full Coverage Health Insurance DTap/Tdap/Td YES YES YES NO NO YES YES YES YES NO Polio YES YES YES NO NO YES YES YES YES NO MMR YES YES YES NO NO YES YES YES YES NO Hib YES YES YES NO NO YES YES YES YES NO Hepatitis B YES YES YES NO NO YES YES YES YES NO Any combination vaccine involving YES YES YES NO NO YES YES YES YES NO antigens above Varicella YES YES YES NO NO YES YES YES YES NO MMR-V (ProQuad) YES YES YES NO NO YES YES YES YES NO Hepatitis A YES YES YES NO NO YES YES YES YES NO Pneumococcal Conjugate Vaccine YES YES YES NO NO YES YES YES YES NO (Prevnar) Pneumococcal Polysaccharide YES YES YES NO NO YES YES YES YES NO Vaccine Meningococcal Conjugate (Menactra) YES YES YES NO NO YES YES YES YES NO Rotavirus Vaccine (RotaTeq, Rotarix) YES YES YES NO NO YES YES YES YES NO Human Papilloma Virus (Gardasil) YES YES YES NO NO YES YES YES YES NO Influenza YES YES YES NO NO YES YES YES YES NO

5 Keep VFC program records for (3) years Must make these records available to public health officials, including the City or Department of Health and Human Services (DHHS), upon request Recordkeeping includes all paper-based or electronic records, including but not limited to: patient screening/eligibility verification and documentation temperature logs, vaccine orders shipping invoices vaccine purchase and accountability records VFC training records, Routine and Emergency Vaccine Management Plans, Provider Recertification forms, etc.).

6 Document immunizations in medical charts Maintain immunization records in accordance with the National Childhood Vaccine Injury Compensation Act (NCVIA) - Clinic/facility address where the vaccine was administered - Date vaccine was administered - Vaccine type - Vaccine manufacturer - Vaccine lot number - Signature and title of person(s) administering vaccine. - Publication date of VIS (located at the bottom of VIS) - Date VIS was given to the patient, parent, or legal representative (usually the same as the vaccine administration date, but still needs to be documented).

7 Charge Only Allowable Fees Providers CANNOT bill anyone for the cost of VFC-supplied vaccines Charge non-medicaid VFC eligible children up to the current federal maximum regional administration fee of $23.87 per vaccine dose (not antigen) uninsured & AI/NA Underinsured at FQHCs VFC providers cannot deny administration of VFC vaccine to an established VFC-eligible patient because the child's parent/guardian inability to pay the administration fee

8 Comply with ACIP Schedule VFC vaccines must be offered and administered according to the guidelines outlined by the Advisory Committee on Immunization Practices (ACIP) in VFC resolutions Providers must comply with immunization schedules, dosages, and contraindications that are established by ACIP and included in the VFC program for populations served, unless: In the provider's medical judgment, and in accordance with accepted medical practice, the provider deems such compliance to be medically inappropriate; The particular requirements contradict state law, including laws pertaining to religious and other exemptions.

9 Vaccine Loss/Replacement Policy When restitution is required - provider will receive letter detailing the number of vaccine doses requiring restitution Providers must reimburse the cost of vaccine lost due to fraud, abuse, or negligence (Dose-per-dose replacement) Provider will have 45 days to replace vaccine If replacement of vaccine, not made after 45 days, providers vaccine ordering will be suspended During 2013, providers were charged $185,000 for vaccine loss most of the loss was due to expired vaccine Total expired/wastage cost to program in million dollars

10 Steps to minimize vaccine waste Provide adequate vaccine storage and monitor storage conditions Do not over-order or stockpile vaccine Never assume vaccine is nonviable in the event of a storage problem. Contact the Chicago VFC Program immediately for instructions. Conduct count of vaccine inventory at least monthly Check vaccine expiration dates at least monthly Rotate vaccine stock regularly; move earliest expiration dates to the front Report vaccine that will not be used and will expire within 90 days (3 months) to the Chicago VFC Program

11 Medicaid Fraud and Abuse Policy Chicago VFC Medicaid Fraud and Abuse policy provides guidance in the monitoring and prevention of fraud, waste and abuse of VFC vaccines Policy is consistent with standards established in the policy on fraud and abuse by the CDC Policy applies to any fraud or abuse or suspected fraud or abuse involving VFC providers Policy is updated yearly and included as part of re-enrollment

12 Medicaid Fraud and Abuse Policy For the purposes of consistency, definitions of fraud and abuse are derived from CMS which supplies the following definitions: Fraud Fraud is defined as an intentional deception or misrepresentation made by a person with the knowledge that the deception could result in some unauthorized benefit to himself or some person. It includes any act that constitutes fraud under applicable federal or state law.

13 Medicaid Fraud and Abuse Policy Abuse Abuse is defined as provider practices that are inconsistent with sound fiscal, business or medical practices, and result in an unnecessary cost to the Medicaid program, (and/or including actions that result in an unnecessary cost to the immunization program, a health insurance company, or a patient);or in reimbursement for services that are not medically necessary or fail to meet professionally recognized standards for health care. It also includes recipient practices that result in unnecessary cost to the Medicaid program.

14 2014 Re-enrollment CDC requirement - VFC providers are required to submit a reenrollment form every year Provider Enrollment form provides clinic information: Name of clinic Vaccine Delivery/Mailing Information Shipping hours Type of clinic (i.e., private, FQHC, school-based clinic) Provider Agreement form is the provider s agreement to comply with all the (18) conditions of the Chicago VFC program Agreement must be reviewed and signed by the medical director, or equivalent in a group practice.

15 2014 Re-enrollment On the Provider List, include the medical license number and NPI (National Provider Identifier) number for each healthcare provider who is prescribing vaccines. If necessary, use additional sheet to include all providers in the practice

16 2014 Re-enrollment (Profiles) STEP profiles have been prepopulated for each VFC clinic ordering data from the last (2) years was used Review the pre-populated numbers If you don t agree with the pre-populated numbers Complete the provider petition form Submit to the program for review and approval

17 2014 Re-enrollment (Profiles) STEP 2 If you agree with the pre-populated numbers: Enter how many VFC eligible patients you see based on VFC eligibility categories

18 2014 Re-enrollment (Profiles) Enter how many Non-VFC eligible patients you serve STEP 3

19 2014 Re-enrollment (Profiles) Enter your total patient population (VFC + Non-VFC) STEP 4

20 2014 Re-enrollment Re-Enrollment Check list Provider Agreement (3 pages) Complete provider profile or petition form Policy Acknowledgement Certification Form All completed & signed forms must be returned by Friday, April 18 th If you have questions or have not received your 2014 reenrollment forms, please call Hana Danish at

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