Issue Brief
  1. 85 Fed. Reg. 71142, 71175 (Nov. 6, 2020).

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  2. H. R. 748 § 3713; 85 Fed. Reg. at 71146.

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  3. 85 Fed. Reg. at 71147.

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  4. 80 Fed. Reg. at 41322.

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  5. H.R. 748 § 3203.

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  6. 85 Fed. Reg. at 71175.

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  7. 85 Fed. Reg. at 71175.

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  8. 85 Fed. Reg. at 71175.

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  9. Department of Health and Human Services, “Putting America’s Health First: FY 2021 President’s Budget for HHS,” p. 46. Available at: https://www.hhs.gov/sites/default/files/fy-2021-budget-in-brief.pdf?language=en

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  10. Children whose health insurance covers the cost of vaccinations are not eligible for VFC vaccines, even if the vaccine is subject to the plan’s deductible. Underinsured children are eligible to receive vaccines only at Federally Qualified Health Centers or Rural Health Clinics.

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  11. 42 U.S.C. § 300gg-13.

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  12. Children enrolled in the Children’s Health Insurance Program through Medicaid expansion CHIP have the same coverage as other children with Medicaid. Children with separate CHIP coverage are considered to have private health insurance. A list of CHIP program names and the type of program in each state is available at https://www.kff.org/other/state-indicator/chip-program-name-and-type/?currentTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%7D.

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  13. 42 U.S.C. § 1396s (d)(3).

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  14. 42 U.S.C. § 1396s (d)(6).

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  15. 85 Fed. Reg. at 71149.

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  16. 85 Fed. Reg. at 71149.

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  17. 42 U.S.C. § § 1396a (k)(1); 1396u-7; 18022; 42 C.F.R. § 440.345 (d).

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  18. 24 of 39 states in a CDC study. Granade CJ, McCord RF, Bhatti AA, Lindley MC. State Policies on Access to Vaccination Services for Low-Income Adults. JAMA Netw Open. 2020;3(4):e203316. doi:10.1001/jamanetworkopen.2020.3316

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  19. 12 of 44 states in a CDC study. Granade CJ, McCord RF, Bhatti AA, Lindley MC. State Policies on Access to Vaccination Services for Low-Income Adults. JAMA Netw Open. 2020;3(4):e203316. doi:10.1001/jamanetworkopen.2020.3316

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  20. Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, 85 Fed. Reg. 71142 (Nov. 6, 2020), https://www.federalregister.gov/documents/2020/11/06/2020-24332/additional-policy-and-regulatory-revisions-in-response-to-the-covid-19-public-health-emergency.

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  21. CMS has stated vaccines are optional for pregnant women covered by CHIP, though it notes that all states covering this population do provide vaccines. Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, 85 Fed. Reg. 71142 (Nov. 6, 2020), https://www.federalregister.gov/documents/2020/11/06/2020-24332/additional-policy-and-regulatory-revisions-in-response-to-the-covid-19-public-health-emergency.

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  22. https://www.medicaid.gov/chip/benefits/index.html

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  23. https://www.medicaid.gov/sites/default/files/2019-11/chip-vaccines.pdf

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  24. 42 U.S.C. § § 1396a (a)(14); 1396o.

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  25. https://www.kff.org/medicaid/issue-brief/data-note-medicaids-role-in-providing-access-to-preventive-care-for-adults/ and http://files.kff.org/attachment/preventive-services-covered-by-private-health-plans-under-the-affordable-care-act-fact-sheet

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  26. Medicaid-eligible children fall under VFC requirements. https://www.cms.gov/files/document/03052020-medicaid-covid-19-fact-sheet.pdf

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  27. For children with CHIP, well-child visits including immunizations must be covered without “deductibles, coinsurance, or other cost sharing” 42 U.S.C. § 1397cc (c), (e).

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  28. 42 U.S.C. § 1396r-8 (k)(2)-(4).

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  29. Pursuant to 42 U.S.C. § 1396a (a)(30)(A), state Medicaid programs must ensure that provider payments are “consistent with efficiency, economy, and quality of care and are sufficient to enlist enough providers. . . .”

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  30. Most states deliver services through capitated managed care, which means states make a set per member per month payment. https://www.kff.org/medicaid/issue-brief/10-things-to-know-about-medicaid-managed-care/

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  31. Payment rates are set differently for FFS Medicaid and for managed care Medicaid. See https://www.macpac.gov/medicaid-101/provider-payment-and-delivery-systems/

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  32. 41 of 49 states make a payment under FFS Medicaid and the median payment is $13.62 Granade CJ, McCord RF, Bhatti AA, Lindley MC. State Policies on Access to Vaccination Services for Low-Income Adults. JAMA Netw Open. 2020;3(4):e203316. doi:10.1001/jamanetworkopen.2020.3316

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  33. Granade CJ, McCord RF, Bhatti AA, Lindley MC. State Policies on Access to Vaccination Services for Low-Income Adults. JAMA Netw Open. 2020;3(4):e203316. doi:10.1001/jamanetworkopen.2020.3316

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  34. Granade CJ, McCord RF, Bhatti AA, Lindley MC. State Policies on Access to Vaccination Services for Low-Income Adults. JAMA Netw Open. 2020;3(4):e203316. doi:10.1001/jamanetworkopen.2020.3316

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  35. This requirement does not apply to populations with limited benefit packages, for example, family planning services, TB-related services and the new COVID-19 testing group. Instead, CMS directs providers to seek reimbursement through the HRSA Provider Relief Fund. See Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, 85 Fed. Reg. 71142 (Nov. 6, 2020); https://www.federalregister.gov/documents/2020/11/06/2020-24332/additional-policy-and-regulatory-revisions-in-response-to-the-covid-19-public-health-emergency.

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  36. Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency, 85 Fed. Reg. 71142 (Nov. 6, 2020); https://www.federalregister.gov/documents/2020/11/06/2020-24332/additional-policy-and-regulatory-revisions-in-response-to-the-covid-19-public-health-emergency.

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  37. Ibid.

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  38. Enhanced federal funding and test/treatment requirements expire at the end of the quarter in which the PHE ends. See https://www.kff.org/medicaid/issue-brief/medicaid-maintenance-of-eligibility-requirements-issues-to-watch-when-they-end/.

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  39. Department of Health and Human Services, “Fiscal Year 2021 Centers for Disease Control and Prevention Justification of Estimates for Appropriation Committees,” page 51. Available at: https://www.cdc.gov/budget/documents/fy2021/FY-2021-CDC-congressional-justification.pdf

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  40. Section 317 vaccines funds may be used for children in the following specific circumstances: to vaccinate newborns receiving the birth dose of hepatitis B prior to hospital discharge that are covered under bundled delivery or global delivery package (no routine services can be individually billed) that does not include hepatitis B vaccine and also fully insured infants of hepatitis B infected women.

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  41. Adults not covered for vaccines and therefore eligible for Section 317 vaccines includes adults on Medicaid who do not have coverage for specific vaccines and are eligible for those vaccines through Section 317; adults living in correctional facilities and jails and household or sexual contacts of a hepatitis B infected individuals are also eligible for vaccines through Section 317.

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  42. Institute of Medicine (US) Committee on the Immunization Finance Dissemination Workshops. Setting the Course: A Strategic Vision for Immunization: Part 2 Summary of the Austin Workshop. Washington (DC): National Academies Press (US); 2002.

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  43. 85 Fed. Reg. at 71175.

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  44. 85 Fed. Reg. at 71149. Limited Medicaid benefit packages that may not include vaccine coverage include pregnancy-related services only (in states where this benefit package is not considered minimum essential coverage); tuberculosis-related services only; family planning services only; medically needy services (in states where this benefit package is not considered minimum essential coverage); breast/cervical cancer services only; COVID-19 testing services only; and Section 1115 waivers that provide limited benefit packages such as those focused on the progression of a specific disease.

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  45. Congressional Research Service, “Health Care for Veterans: Answers to Frequently Asked Questions,” March 4, 2020.

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  46. Congressional Research Service, “Health Care for Veterans: Answers to Frequently Asked Questions,” March 4, 2020.

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  47. 38 C.F.R. § 17.108 (e)(11).

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  48. 38 C.F.R. § 17.108 (e)(11).

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