more changes! - city of chicago changes! 2014-2015 vfc program ... • form can be completed by the...
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Chicago Department of Public Health Commissioner Bechara Choucair, M.D.
City of Chicago Mayor Rahm Emanuel
More Changes! 2014-2015 VFC Program
Recommendations and Requirements Maribel Chavez-Torres, MPH
Immunization Program Director
2014-2015 VFC Program Recommendations and Requirements
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)
2014-2015 VFC Program Recommendations and Requirements
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
Private Health Centers (non-FQHC, non-Public) Federally Qualified Health Centers
VFC Vaccines
VFC Eligibility Categories VFC Eligibility Categories Medicaid Uninsured
(Self-Pay) Am. Indian
Alaskan Native
Under- Insured
HMO/Private Full Coverage
Health Insurance
Medicaid1 Uninsured (Self-Pay)
Am. Indian
Alaskan Native
Under- Insured2
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 antigens above
YES YES YES NO NO YES YES YES YES NO
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 (Prevnar)
YES YES YES NO NO YES YES YES YES NO
Pneumococcal Polysaccharide Vaccine
YES YES YES NO NO YES YES YES YES NO
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
Chicago VFC Program Vaccine Eligibility Reference Table
2014-2015 VFC Program Recommendations and Requirements
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.).
2014-2015 VFC Program Recommendations and Requirements
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).
2014-2015 VFC Program Recommendations and Requirements
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
2014-2015 VFC Program Recommendations and Requirements
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.
2014-2015 VFC Program Recommendations and Requirements
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 2013 2 million
dollars
2014-2015 VFC Program Recommendations and Requirements
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
2014-2015 VFC Program Recommendations and Requirements
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
2014-2015 VFC Program Recommendations and Requirements
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.”
2014-2015 VFC Program Recommendations and Requirements
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.”
2014-2015 VFC Program Recommendations and Requirements
2014 Re-enrollment • CDC requirement - VFC providers are required to submit a re-
enrollment 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.
2014-2015 VFC Program Recommendations and Requirements
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
2014-2015 VFC Program Recommendations and Requirements
2014 Re-enrollment (Profiles) • 2014 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
STEP 1
2014-2015 VFC Program Recommendations and Requirements
2014 Re-enrollment (Profiles) • If you agree with the pre-populated numbers: • Enter how many VFC eligible patients you see based on VFC
eligibility categories
STEP 2
2014-2015 VFC Program Recommendations and Requirements
2014 Re-enrollment (Profiles) • Enter how many Non-VFC eligible patients you serve
STEP 3
2014-2015 VFC Program Recommendations and Requirements
2014 Re-enrollment (Profiles) • Enter your total patient population (VFC + Non-VFC)
STEP 4
2014-2015 VFC Program Recommendations and Requirements
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 18th
• If you have questions or have not received your 2014 re-enrollment forms, please call Hana Danish at 312-746-5375
facebook.com/ChicagoPublicHealth @ChiPublicHealth
312.747.9884
www.CityofChicago.org/Health