Recent Centers for Medicare & Medicaid Services guidance clarifies an important point about Medicare Part B vaccine billing that could affect reimbursement for your clinic.
What changed?
CMS clarified that beginning July 1, 2025, Rural Health Clinics and Federally Qualified Health Centers are required to bill Medicare for eligible Part B preventive vaccines and their administration. Earlier communications used language that led many providers to believe billing was optional.
Reminder: Hepatitis B vaccines became eligible Medicare Part B preventive vaccines on January 1, 2025. Medicare now pays for hepatitis B vaccines the same way it pays for pneumococcal, influenza, and COVID-19 vaccines.
Why this matters
Many RHCs and FQHCs continued using the previous roster billing approach based on their interpretation of the earlier guidance.
The concern is that vaccine claims must appear on the Provider Statistical & Reimbursement report that supports your cost report. If eligible vaccines are not billed and do not appear on the PS&R, the associated vaccine costs may not be reimbursed through the cost report process.
Which vaccines are affected?
The requirement applies to Medicare Part B preventive vaccines and their administration, including:
- Influenza
- Pneumococcal
- COVID-19
- Hepatitis B
What should your facility do?
If your clinic has not been billing Medicare for these vaccines:
- Review vaccine logs and records for eligible Medicare vaccine services.
- Submit claims for outstanding eligible vaccines as soon as possible.
- Monitor timely filing deadlines to avoid denied claims.
- Confirm that billed vaccines are appearing on the PS&R report used to prepare your cost report.
If you were planning to rely on vaccine logs to support reimbursement through the cost report process, those vaccines must now be billed to Medicare so they are reflected on the PS&R report.
References
- Payment for Medicare Part B Preventive Vaccines & Their Administration for Rural Health Clinics & Federally Qualified Health Centers (PDF)
- June 2026 WPS Provider Audit Webinar
Contact us
If you have questions about this latest clarification or need help with your cost reports, let us know.