PPL 21-040: Notification of Reimbursement for COVID-19 Vaccinations in the LEA Billing Program

Last Wednesday, December 15, DHCS released an email regarding Policy and Procedure Letter 21-040 titled “Notification of Reimbursement for COVID-19 Vaccinations in the LEA Billing Program.” This may be confusing; as you’ll recall, DHCS had published another PPL 21-040 back on December 8, which was a duplication of PPL 21-034. Well, it turns out, as we suspected, that the December 8 PPL 21-040 was a mistake, and the correct PPL is that which was released on December 15.

This corrected PPL 21-040 confirms that COVID-19 vaccines are considered a covered EPSDT service authorized under the Bright Futures Recommendations for Preventive Pediatric Health Care (Periodicity Schedule) and, therefore, are a billable treatment service when provided to Medi-Cal enrolled students ages 5-12 by a qualified practitioner. An IEP, IFSP, or Care plan is not required in order for LEAs to bill for this service. However, similar to all immunizations under the Periodicity Schedule, parent consent must be received. This PPL further states that time spent administering a COVID-19 vaccine must meet a 15-minute time threshold in order to bill one unit of service. The additional components that can be included to meet the 15-minute increment are:

  • Preparation activities prior to the administration of the vaccine (e.g., reviewing documents to ensure they are complete, screening recipients for contraindications and precautions, and confirming consent was provided to vaccinate a Medi-Cal student ages 5 through 17);
  • Administration of the vaccine, including gathering supplies and performing hand and injection site hygiene; and
  • Follow-up activities conducted after the administration of the vaccine (e.g., documenting the service, completing the vaccination card, and observing the beneficiary for possible adverse health events).

The effective date for COVID-19 vaccines administered to students ages 5-11 is October 29, 2021, and May 10, 2021, for students aged 12.

This opportunity to garner additional reimbursements for COVID-19 vaccinations is well received, and Paradigm will be rolling out new SHN features in the new year that will make billing for this service even easier. If you have any questions or want to discuss this further, please do not hesitate to contact your account manager.