C-TAC has submitted comments in response to the fourth Interim Final Rule, released by the Centers for Medicare & Medicaid Services. We expressed support for the overall goal of the rule to clarify policies that are intended to support COVID-19 vaccine reimbursement and distribution, given the great potential a successful national vaccination campaign has to ultimately help control this pandemic and allow for the resumption of a more stable healthcare system.
We did share concerns about the rule’s blended interpretation of vaccine coverage, which could exclude federal funding from states that want to extend immunization coverage to special limited coverage groups. We believe this approach may have the unintended consequence of leaving people with the lowest means who rely on community services or volunteer programs without access to the vaccine.
