COVID-19 Vaccine Incentives: CMS Guidance Needed to Help Medicaid Programs Go Further

By Clive Riddle, April 23, 2021

A major worry is that COVID-19 vaccine takeup, which had been rocketing upward, may now have reach a plateau. Here’s how the Kaiser Family Foundation frames the situation: “Broadly, the COVID-19 Vaccine Monitor has found that vaccine confidence in the U.S. has increased as more and more people have seen their friends and family members get vaccinated, and now a majority of the public has either already gotten vaccinated or is ready to get the vaccine as soon as they can. Yet with a small but persistent group opposed to getting the vaccine and many others still on the fence, the U.S. may soon hit a point where vaccine supply exceeds demand, a situation that is already the case in certain communities.”

Health Plans across the country are announcing various incentive measures to encourage COVID-19 vaccinations:

• Cigna just announced emergency time off and a $200 incentive for Cigna employees to receive the vaccination, and also a program for free Transportation for Medicare Advantage Customers to Vaccine Appointments.
• Florida Blue just announced they are is teaming with Lyft and other transportation companies to offer its members access to rides to and from vaccination appointments as part of its services to support vaccination events across the state.
• Earlier this week AHIP published a summary of health plan initiatives to improve vaccine acceptance and access, list specific measures taken by over 40 regional and national plan.  Included was mention that CalOptima, a Southern California Medicaid plan, is “launching a Vaccination Incentive Program to offer two $25 nonmonetary gift cards to CalOptima Medi-Cal members who get both required doses of the COVID-19 vaccine, subject to state regulatory approval.”

While health plans must be lauded for proactively taking these steps, unfortunately, CalOptima was the only one specifically mentioned with programs targeting Medicaid populations.  Concerns certainly continue about health care equity in fighting COVID-19.

But the lack of announced Medicaid plan and state program vaccine incentive initiatives can’t really be blamed on the health plan industry. Notice that mention of the CalOptima incentive was “subject to state regulatory approval.” And higher up than that, guidance from CMS is still pending.  The CMS web page: Beneficiary Incentives for COVID-19 Vaccine Shots still states “CMS will provide more information about whether we'll allow patient incentives for COVID-19 vaccination during the public health emergency (PHE).”

Specific to Medicaid, the current (published March 15^th) CMS guidance in their State Resource Center: Coverage and Reimbursement of COVID-19 Vaccines, Vaccine Administration, and Cost Sharing under Medicaid, the Children’s Health Insurance Program, and Basic Health Program, with regard to vaccine incentives, states: “Beneficiary incentives: CMS will be providing more information regarding whether beneficiary incentives will be permitted in connection with COVID-19 vaccination during the PHE.”

The health plan initiatives for Medicare Advantage and employer based plans are certainly to be commended, but the vaccine takeup rates for seniors are higher overall, and employer based covered populations do have greater resources than the general Medicaid covered populations. Would not public policy greatly benefit from CMS proactive encouragement of state programs and private Medicaid plans offering incentives including gift cards and cost sharing credits for other plan services?