Page 2  State Health Official  
 
 
Additionally, section 9811 of the American Rescue Plan Act of 2021 (Pub. L. No. 117-2) (ARP) 
requires state Medicaid programs to cover COVID-19 vaccine administration without cost-
sharing and makes a 100 percent Federal Medical Assistance Percentage (FMAP) temporarily 
available for state Medicaid expenditures on COVID-19 vaccines and their administration.   
 
CMS interprets the references in ARP section 9811 to the administration of a COVID-19 
vaccine, including in section 1905(a)(4)(E) and (hh) of the Social Security Act (the Act), to 
include stand-alone COVID-19 vaccine counseling, when this counseling is covered for 
Medicaid beneficiaries under the age of 21 who are eligible for EPSDT.   
 
State expenditures on stand-alone COVID-19 vaccine counseling are federally matched at 100 
percent under the ARP only when this counseling is provided to Medicaid beneficiaries who are 
eligible both for EPSDT and the COVID-19 vaccination coverage required under the ARP.  
States have the option to cover stand-alone vaccine counseling for Medicaid beneficiaries who 
are not eligible for EPSDT.  State expenditures on stand-alone COVID-19 vaccine counseling for 
beneficiaries not eligible for EPSDT, and state expenditures on stand-alone vaccine counseling 
related to vaccines other than COVID-19 vaccines, are federally matched at the otherwise 
applicable FMAP, not at the ARP 100 percent FMAP.   
 
Because EPSDT is not a requirement in a separate CHIP, different policies apply in separate 
CHIPs, as discussed below.  
 
Background 
 
As of January 2022, Medicaid and CHIP enrollment totaled approximately 86.9 million 
individuals, including over 40.1 million children.5 The number of children enrolled represents 
47.3 percent of total Medicaid and CHIP enrollment. Medicaid beneficiaries currently have some 
of the lowest reported COVID-19 vaccination rates among those for whom the COVID-19 
vaccines are recommended.6  
 
Stand-alone vaccine counseling has been shown to help address vaccine hesitancy by helping 
beneficiaries and their families learn about vaccines from trusted health care providers. Coverage 
of stand-alone vaccine counseling could help states increase COVID-19 and other vaccination 
rates for Medicaid and CHIP beneficiaries, especially among children.  Survey data have shown 
that a large percentage of parents are hesitant to have their children vaccinated, even when they 
have received the COVID-19 vaccination themselves, and that they are most comfortable having 
their children vaccinated by their trusted health care provider.7  The American Academy of 
Pediatrics (AAP) recommends that providers address parental questions regarding vaccines and 
                                                            
5 https://www.medicaid.gov/medicaid/program-information/medicaid-and-chip-enrollment-data/report-
highlights/indexhtml.   
6 https://www.commonwealthfund.org/blog/2021/how-can-states-improve-covid-19-vaccination-rates-in-medicaid 
7 https://www.medicaid.gov/state-resource-center/downloads/cmcs-all-state-call-11092021.pdf  
 
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 3  State Health Official  
 
notes the importance of counseling to address parental anxiety and misinformation.8  This is 
particularly vital for parents of children with disabilities and chronic conditions, many of whom 
the Centers for Disease Control and Prevention (CDC) advises may be at higher risk than their 
peers for severe outcomes of COVID-19.9 Additionally, data indicates that people from racial 
and ethnic minority groups are more likely to die from COVID-19 at younger ages than non-
Hispanic white people.10 
During the COVID-19 Public Health Emergency (PHE), there has been a decline in the number 
of all childhood vaccines provided to Medicaid and CHIP populations, except for influenza.11 
Vaccine counseling is an important tool available for all vaccinations, but is particularly 
important during the COVID-19 PHE, as families seek to have their children receive routine 
vaccinations and well-child visits.  
 
Coverage of Stand-alone Vaccine Counseling  
 
Medicaid Coverage of Stand-alone Vaccine Counseling  
 
States have long had the option to cover stand-alone vaccine counseling in Medicaid.  State 
expenditures on this counseling have historically been federally matched at the regularly 
applicable FMAP.   
Coverage of Stand-alone Vaccine Counseling for Beneficiaries Eligible for EPSDT 
 
As of December 2, 2021, CMS interprets the Medicaid EPSDT benefit to require states to 
provide coverage of stand-alone vaccine counseling to Medicaid beneficiaries under the age of 
21 who are eligible for EPSDT.  This interpretation is based on section 1905(r)(1)(B)(v) of the 
Act, under which states are required to cover health education as part of the EPSDT benefit.  
Under this updated interpretation of the EPSDT benefit, states must cover stand-alone vaccine 
counseling for all vaccines covered under EPSDT, including both COVID-19 and non-COVID-
19 vaccines, regardless of the federal matching percentage for their expenditures on the stand-
alone vaccine counseling.  States may establish limits on the number of times stand-alone 
vaccine counseling is covered for a beneficiary eligible for EPSDT, as long as the limits can be 
exceeded based on medical necessity. Stand-alone vaccine counseling may also be covered when 
provided via telehealth, at state option.12   
 
Coverage of Stand-alone COVID-19 Vaccine Counseling for Beneficiaries Eligible for EPSDT 
 
Section 9811 of the ARP established a mandatory Medicaid benefit at section 1905(a)(4)(E) of 
the Act for COVID-19 vaccines and their administration and amended various sections of the 
                                                            
8 https://publications.aap.org/pediatrics/article/138/3/e20162146/52702/Countering-Vaccine-Hesitancy 
9   https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-care/underlyingconditions.html#accordion-1-card- 
10 https://www.cdc.gov/coronavirus/2019-ncov/hcp/clinical-care/underlyingconditionshtml#accordion-1-card- 
11 https://www.medicaid.gov/state-resource-center/downloads/covid-19-medicaid-data-snapshot-08-31-2021.pdf  
12 States generally have a great deal of flexibility with respect to covering Medicaid services provided via telehealth.  
See https://www.medicaid.gov/medicaid/benefits/downloads/medicaid-chip-telehealth-toolkit.pdf. 
 
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 4  State Health Official  
 
Act, including sections 1902(a)(10), 1905, 1916(a)(2), 1916(b)(2), 1916A(b)(3)(B), and 1937 of 
the Act.13  Under the ARPs amendments, state Medicaid programs must cover COVID-19 
vaccine administration without cost-sharing, for a specified period of time, and 100 percent 
FMAP is available for state Medicaid expenditures on COVID-19 vaccine administration.14 The 
requirement to cover COVID-19 vaccines and their administration without cost-sharing generally 
applies beginning March 11, 2021 and ending on the last day of the first calendar quarter that 
begins one year after the last day of the COVID-19 PHE (referred to herein as the ARP 
coverage period).15 The applicable period for the 100 percent FMAP is slightly different, as 
discussed further below. 
 
CMSs interpretation of the EPSDT benefit to include stand-alone vaccine counseling affects 
how CMS interprets the amendments made by the ARP.  Specifically, as of December 2, 2021, 
CMS interprets the references in ARP section 9811 to the administration of a COVID-19 
vaccine, including in section 1905(a)(4)(E) and (hh) of the Act, to include stand-alone COVID-
19 vaccine counseling, when this counseling is covered for Medicaid beneficiaries under the age 
of 21 who are eligible both for EPSDT and the ARP COVID-19 vaccination coverage.16  This 
means that states are required to cover this counseling for those beneficiaries, without cost-
sharing.  An overview of how CMS interprets the Medicaid statute to require coverage of this 
stand-alone COVID-19 vaccine counseling was provided to states on the CMS All-State Call 
held on December 9, 2021 and the corresponding presentation can be accessed on 
Medicaid.gov.17  
 
Additionally, CMS will match state expenditures on stand-alone COVID-19 vaccine counseling 
for Medicaid beneficiaries who are eligible both for EPSDT and the ARP COVID-19 vaccination 
coverage at the 100 percent FMAP available under the ARP for state expenditures on COVID-19 
vaccine administration.  This 100 percent FMAP is available beginning on April 1, 2021 and 
ending on the last day of the first quarter that begins one year after the last day of the COVID-19 
PHE (referred to herein as the ARP FMAP period).18   
 
                                                            
13 For more information on the COVID-19 vaccination coverage requirements under the ARP, see section II of 
Coverage and Reimbursement of COVID-19 Vaccines, Vaccine Administration, and Cost-Sharing under Medicaid, 
the Childrens Health Insurance Program, and Basic Health Program (Vaccine Toolkit), 
https://www.medicaid.gov/state-resource-center/downloads/covid-19-vaccine-toolkit.pdf. 
14 Nearly all Medicaid beneficiaries are eligible for this coverage, but there are a few limited exceptions. For 
example, persons eligible only for Medicaid coverage of Medicare premiums under sections 1902(a)(10)(E) or 1933 
of the Act are not eligible for it.  See ARP  9811 generally, and, in particular, ARP  9811(a)(2)(F) (adding clause 
XIX to the language following section 1902(a)(10)(G) of the Act). 
15 The optional COVID-19 group at section 1902(a)(10)(A)(ii)(XXIII) of the Act receives this coverage only 
through the last day of the COVID-19 PHE. No federal financial participation is available for any state expenditures 
on benefits for this group, including coverage of COVID-19 vaccinations, after the PHE ends.  
16 https://www.cms.gov/newsroom/press-releases/biden-harris-administration-makes-100-federal-medicaid-
matching-funds-available-state-expenditures.  
17 https://www.medicaid.gov/state-resource-center/downloads/vaccine-counseling-for-medicaid-chip-
beneficiaries.pdf 
18 For more information about the ARP 100 percent FMAP and the ARP FMAP period, see State Health Official 
(SHO) Letter #21-004 at https://wwwmedicaid.gov/federal-policy-guidance/downloads/sho-21-004.pdf 
 
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 5  State Health Official  
 
After the ARP FMAP period expires, federal matching for state Medicaid expenditures on 
COVID-19 vaccine administration, including on stand-alone COVID-19 vaccine counseling for 
persons who are eligible both for EPSDT and the ARP COVID-19 vaccination coverage, will 
revert to the regularly applicable FMAP.   
 
These policies only apply when stand-alone COVID-19 vaccine counseling is covered for 
persons who are eligible both for EPSDT and the ARP COVID-19 vaccination coverage.   
 
Coverage of Stand-alone Vaccine Counseling for Beneficiaries Not Eligible for EPSDT 
There is no benefit or coverage requirement comparable to EPSDT or its health education 
requirement for Medicaid beneficiaries age 21 and older.  Additionally, some Medicaid 
beneficiaries under age 21 are not eligible for EPSDT.  However, states continue to have the 
option to cover stand-alone vaccine counseling (including stand-alone vaccine counseling related 
to the COVID-19 vaccines) for Medicaid beneficiaries who are not eligible for EPSDT.  State 
expenditures on stand-alone COVID-19 and other vaccine counseling for all Medicaid 
beneficiaries who are not eligible for EPSDT will be matched at the applicable FMAP, not at the 
ARP 100 percent FMAP. 
CHIP Coverage of Stand-alone Vaccine Counseling 
 
Section 9821 of the ARP added a mandatory COVID-19 vaccination benefit for separate CHIPs 
at section 2103(c)(11)(A) of the Act and amended section 2103(e)(2) of the Act.  The changes 
require coverage of COVID-19 vaccines and their administration without cost-sharing for all 
separate CHIP enrollees, and apply during the same time period as the Medicaid coverage 
requirements under section 9811 of the ARP.  Section 9821 of the ARP also amended the CHIP 
statute to provide for a 100 percent CHIP federal matching rate for state expenditures on 
COVID-19 vaccine administration during the ARP FMAP period.   
 
Because EPSDT is not a requirement in a separate CHIP and there is no benefit or coverage 
requirement comparable to EPSDT or its health education requirement for individuals in a 
separate CHIP, CMS does not interpret the references to COVID-19 vaccine administration 
added to the CHIP statute under section 9821 of the ARP to include stand-alone vaccine 
counseling related to a COVID-19 vaccine for a beneficiary in a separate CHIP.  Therefore, 
separate CHIPs are not required to cover stand-alone COVID-19 vaccine counseling for 
beneficiaries under age 21, and states will not receive 100 percent federal matching funds under 
section 9821 of the ARP for their expenditures on this stand-alone vaccine counseling.  States 
may opt to cover stand-alone COVID-19 and other vaccine counseling for children and pregnant 
adults enrolled in a separate CHIP, but are not required to do so.  Expenditures for this stand-
alone vaccine counseling will be matched at the states enhanced federal matching percentage for 
Title XXI beneficiaries, not at the 100 percent federal matching percentage for COVID-19 
vaccine administration under section 9821 of the ARP.  Even though states are not required to 
cover stand-alone vaccine counseling in a separate CHIP, the majority of states have elected to 
follow the AAP Bright Futures periodicity schedule for preventive pediatric health care, which 
emphasizes the importance of vaccine counseling as part of CHIP required well-baby/well-child 
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 6  State Health Official  
 
visits.19   
 
Since CMS published its December 9, 2021 slide deck on this updated interpretation of the 
EPSDT benefit, states and other members of the public have asked about the federal matching 
rate for state expenditures on stand-alone COVID-19 vaccine counseling in Medicaid-expansion 
CHIPs.  Beneficiaries enrolled in a Medicaid-expansion CHIP under 42 CFR  435.118 or 
 435.229 are eligible for EPSDT, and states are required to cover stand-alone vaccine 
counseling for all pediatric vaccines covered under EPSDT for all such Medicaid-expansion 
CHIP beneficiaries.  State expenditures on stand-alone COVID-19 vaccine counseling for these 
Medicaid-expansion CHIP beneficiaries will be federally matched at the 100 percent federal 
matching rate for COVID-19 vaccine administration under section 9821 of the ARP during the 
ARP FMAP period.  State expenditures on stand-alone vaccine counseling provided to these 
Medicaid-expansion CHIP beneficiaries about all other vaccines required under the EPSDT 
benefit (i.e., non-COVID-19 vaccines) will be federally matched at the states enhanced federal 
medical assistance percentage for Title XXI beneficiaries, not at the ARP 100 percent federal 
matching rate.  
 
Medicaid and CHIP Coverage of Visits During which Beneficiaries Receive Both Counseling 
about COVID-19 Vaccination and the COVID-19 Vaccine Itself 
CMS considers all visits during which a COVID-19 vaccine is actually delivered or injected to 
include COVID-19 vaccine administration under the ARP, regardless of whether counseling 
about the COVID-19 vaccine is also provided during the same visit.  States are required to cover 
any actual delivery of a COVID-19 vaccine, without cost-sharing, for all CHIP beneficiaries and 
for all Medicaid beneficiaries eligible for COVID-19 vaccine administration coverage under the 
ARP.  States expenditures on the COVID-19 vaccine delivery provided during such visits will 
be federally matched at 100 percent in both Medicaid and CHIP during the ARP FMAP period,20 
regardless of whether counseling about COVID-19 vaccination is also provided during the same 
visit, and regardless of whether the visit is provided to a person who is eligible for EPSDT.    
 
Qualified Providers 
 
States may have licensure and scope of practice laws governing who is authorized under state 
law to administer vaccinations. Additionally, some federal Medicaid and CHIP regulations 
defining benefits under which states might opt to cover vaccine administration expressly refer to 
state licensure or scope of practice laws, by requiring that services be prescribed, furnished, 
recommended, or provided by practitioners acting within their scope of practice as defined by 
state law.  For example, 42 CFR  440.60 requires that Medicaid other licensed practitioner 
services be provided by practitioners acting within the scope of practice as defined under state 
law, and 42 CFR  440.130(c) requires that Medicaid preventive services be recommended by 
                                                            
19 https://downloads.aap.org/AAP/PDF/periodicity schedule.pdf; 
https://brightfutures.aap.org/Bright%20Futures%20Documents/BF4 POCKETGUIDE.pdf (see pp. 10-11).  
20 See SHO Letter #21-004 for CMS guidance about allocation methods states should follow to appropriately 
identify and report expenditures associated with COVID-19 vaccine administration in circumstances where states 
make a bundled payment to providers for services that include COVID-19 vaccine administration.  
https://www.medicaid.gov/federal-policy-guidance/downloads/sho-21-004.pdf.  
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 7  State Health Official  
 
practitioners acting within the scope of authorized practice under state law.    
 
As is discussed in greater detail in Coverage and Reimbursement of COVID-19 Vaccines, 
Vaccine Administration, and Cost-Sharing under Medicaid, the Childrens Health Insurance 
Program, and Basic Health Program (the Vaccine Toolkit), the Secretary of Health and Human 
Services (HHS) issued a declaration under the Public Readiness and Emergency Preparedness 
(PREP) Act that authorizes certain practitioners to administer COVID-19 vaccines, subject to 
certain conditions set forth in the declaration.21  The HHS COVID-19 PREP Act declaration also 
authorizes certain pharmacy practitioners to administer childhood vaccines to children ages three 
(3) through 18.22   
 
The HHS Office of the General Counsel and Department of Justice Office of Legal Counsel 
issued advisory opinions explaining that the PREP Act and the HHS COVID-19 PREP Act 
declaration preempt state laws that would otherwise prohibit or effectively prohibit licensed 
pharmacists from ordering and administering covered countermeasures described in the HHS 
COVID-19 PREP Act declaration.23  Based on the reasoning set forth in these opinions, state 
laws are also preempted if they would prohibit or effectively prohibit persons authorized to 
administer COVID-19 or childhood vaccines under the HHS COVID-19 PREP Act declaration 
from doing so.  This means that states cannot rely on state law to prevent persons from 
administering COVID-19 or childhood vaccines if they are authorized to do so under the HHS 
COVID-19 PREP Act declaration.   
 
As explained in more detail in the Vaccine Toolkit, because the authorizations in the HHS 
COVID-19 PREP Act declaration preempt conflicting state law, if a person is authorized to 
administer COVID-19 or childhood vaccines under the HHS COVID-19 PREP Act declaration, a 
state may not deny Medicaid or CHIP reimbursement to that person for the vaccine 
administration on the basis of a state law that is preempted by the declaration.  CMS also 
interprets references to practitioners state-law scope of practice in federal Medicaid and CHIP 
laws and regulations as incorporating the PREP Act preemption of state law. In other words, if a 
state law is currently preempted by the PREP Act and HHSs COVID-19 PREP Act declaration 
and authorizations, CMS would interpret a reference to that state law in a federal Medicaid or 
                                                            
21 See Vaccine Toolkit, at section V, https://www.medicaid.gov/state-resource-center/downloads/covid-19-vaccine-
toolkit.pdf.  The Vaccine Toolkit contains citations to the HHS COVID-19 PREP Act declaration and related 
authorizations, but they are also available at https://asprhhs.gov/legal/PREPact/Pages/default.aspx.   
22 See Third Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical 
Countermeasures Against COVID-19, 85 Fed. Reg. 52,136 (Aug. 24, 2020), at 
https://www.govinfo.gov/content/pkg/FR-2020-08-24/pdf/2020-18542.pdf; Eighth Amendment to Declaration 
Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID-19, 86 
Fed. Reg. 41,977 (Aug. 4, 2021), https://www.federalregister.gov/documents/2021/08/04/2021-16681/eighth-
amendment-to-declaration-under-thepublic-readiness-and-emergency-preparedness-act-for.    
23 Advisory Opinion 20-02 on the Public Readiness and Emergency Preparedness Act and the Secretarys 
Declaration under the Act, May 19, 2020, https://wwwhhs.gov/guidance/sites/default/files/hhs-guidance-
documents/advisory-opinion-20-02-hhs-ogc-prep-act.pdf.  See also Department of Justice Office of Legal Counsel 
Advisory Opinion for Robert P. Charrow, General Counsel of the Department of Health and Human Services, 
January 19, 2021, available at: https://www.justice.gov/sites/default/files/opinions/attachments/2021/01/19/2021-01-
19-prep-act-preemption.pdf.   
 
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 8  State Health Official  
 
CHIP statute or regulation to refer instead to the federal law preempting the state law. 
 
Additionally, consistent with Medicaids freedom-of-choice of provider requirement at section 
1902(a)(23)(A) of the Act, CMS will expect states to provide Medicaid coverage for COVID-19 
and childhood vaccinations administered by anyone who is authorized to do so under the HHS 
COVID-19 PREP Act declaration, during any time period when the HHS COVID-19 PREP Act 
declaration authorizations are in effect and Medicaid coverage of the vaccinations is mandatory.  
States still must meet all other applicable federal requirements for covering the applicable 
benefit, such as reimbursing only those providers that are enrolled as Medicaid providers and 
covering vaccinations only for eligible individuals.24     
 
The authorizations under the HHS COVID-19 PREP Act declaration to administer COVID-19 
and childhood vaccines extend to stand-alone vaccine counseling related to these vaccines that is 
provided to Medicaid beneficiaries who are eligible for EPSDT.  CMS has determined that this 
stand-alone vaccine counseling, when provided as part of the EPSDT mandate, is vaccine 
administration.  Thus, states cannot deny Medicaid payment for this stand-alone vaccine 
counseling to practitioners authorized to administer COVID-19 and childhood vaccines under the 
HHS COVID-19 PREP Act declaration on the basis that state law would not authorize the 
practitioner to administer the vaccine in question.  Importantly, the age range for which a 
practitioner is authorized to administer a vaccine under the HHS COVID-19 PREP Act 
declaration may be broader than what is authorized under state law, and if so, the more restrictive 
state law would be preempted.  State Medicaid programs are expected to give all provider types 
authorized to administer COVID-19 and childhood vaccinations under the HHS COVID-19 
PREP Act declaration an opportunity to enroll as Medicaid providers and receive Medicaid 
paymentnot only for actually delivering or injecting the vaccines, but also for stand-alone 
vaccine counseling about these types of vaccinations provided to beneficiaries eligible for 
EPSDT.  It is also important to note that the HHS COVID-19 PREP Act declaration may be in 
effect for longer than the COVID-19 PHE.25 
 
Providers who work in school-based settings might also be qualified providers of COVID-19 or 
childhood vaccine administration, and states would receive 100 percent FMAP during the ARP 
FMAP period in payments to these providers for COVID-19 vaccine administration, including 
for stand-alone COVID-19 vaccine counseling for beneficiaries eligible for EPSDT. 
 
Payment and Claims 
 
Within the parameters of section 1902(a)(30)(A) of the Act, states have flexibility to set payment 
rates for stand-alone vaccine counseling.  States may establish separate payment rates for stand-
alone vaccine counseling, or explore other payment methodologies to recognize additional costs 
                                                            
24 See discussion in section V.C of the Vaccine Toolkit for more information and examples. Although the Vaccine 
Toolkit is focused on COVID-19 vaccinations, the same principles would apply with respect to the HHS COVID-19 
PREP Act declaration authorizations related to administration of childhood vaccines. 
https://wwwmedicaid.gov/state-resource-center/downloads/covid-19-vaccine-toolkit.pdf.  
25  See section XII of the HHS COVID-19 PREP Act declaration, at 87 Fed. Reg. 982, 988 (Jan. 7, 2022), 
https://wwwfederalregister.gov/documents/2022/01/07/2022-00151/tenth-amendment-to-declaration-under-the-
public-readiness-and-emergency-preparedness-act-for-medical.   
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 9  State Health Official  
 
associated with vaccine counseling that are not otherwise paid as part of the states usual 
payment rate for vaccine administration or for a comprehensive office visit.   
 
CMS encourages states to develop a payment methodology for stand-alone COVID-19 vaccine 
counseling that will enable them to identify and document which state expenditures can be 
claimed at 100 percent FMAP because CMS considers them to be COVID-19 vaccine 
administration under the ARP provisions.  For example, states could explore establishing a new, 
additional COVID-19 vaccine administration payment rate that would apply only to stand-alone 
counseling about the COVID-19 vaccines provided to beneficiaries who are eligible both for 
EPSDT and the ARP COVID-19 vaccination coverage.  Such a rate could be separate from, 
and/or in addition to, any rate for COVID-19 vaccine administration that a state might have 
developed for actual injection of the vaccines, provided that the state would not pay a provider 
twice for any costs already built into the states existing rate for COVID-19 vaccine 
administration.  Establishing a separate payment rate for this stand-alone COVID-19 vaccine 
counseling would enable states to make separate payments to providers for that counseling, and 
thus might help states identify and document which expenditures should be claimed at the ARP 
100 percent FMAP during the ARP FMAP period.  States could also modify existing billing 
codes designed to help states and other payers reimburse practitioners for stand-alone COVID-19 
vaccine counseling (see Coding discussion below) to identify when stand-alone COVID-19 
vaccine counseling was furnished to EPSDT-eligible beneficiaries. 
 
States that choose not to establish separate payment rates and associated billing codes for stand-
alone COVID-19 vaccine counseling provided to beneficiaries who are eligible both for EPSDT 
and the ARP COVID-19 vaccination coverage could reimburse for this mandatory coverage 
through existing payment methods such as the payment rate for a comprehensive office visit or 
the payment rate that the state has already established for vaccine administration.  In such cases, 
however, states claiming the ARP 100 percent FMAP must still be able to determine when their 
expenditures on such payments can be matched at 100 percent FMAP during the ARP FMAP 
period.  Not having a separate Healthcare Common Procedure Coding System (HCPCS) code, 
Current Procedural Terminology (CPT) code, or modifier for state expenditures on stand-alone 
COVID-19 vaccine counseling provided to beneficiaries who are eligible both for EPSDT and 
the ARP COVID-19 vaccination coverage could present significant challenges in determining 
which state expenditures can be matched at 100 percent FMAP during the ARP FMAP period.  
States that do not pay a separate fee or use a separate code for stand-alone COVID-19 vaccine 
counseling furnished to EPSDT-eligible beneficiaries will need to work directly with their 
practitioner communities to determine an approach to use to document and identify which state 
expenditures qualify for the 100 percent FMAP.  Alternatively, states may opt not to claim the 
ARP 100 percent FMAP for this stand-alone COVID-19 vaccine counseling, if claiming that 
FMAP would be too administratively and/or operationally burdensome.  
States currently covering stand-alone COVID-19 vaccine counseling for Medicaid beneficiaries 
who are eligible both for EPSDT and the ARP COVID-19 vaccination coverage will be able to 
retroactively adjust claims back to April 1, 2021, to receive the 100 percent FMAP for these 
expenditures during the ARP FMAP period.  States that newly implement Medicaid coverage of 
stand-alone COVID-19 vaccine counseling for beneficiaries who are eligible both for EPSDT 
and the ARP COVID-19 vaccination coverage can claim the 100 percent FMAP for their 
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 10  State Health Official  
 
expenditures on this stand-alone COVID-19 vaccine counseling on or after April 1, 2021, and 
throughout the ARP FMAP period. 
 
CMS will work to ensure appropriate oversight of states claiming and allocation methodologies 
and will place special emphasis on state expenditures claimed at the ARP 100 percent FMAP 
while conducting quarterly and annual financial reviews. 
 
State Plan Amendments (SPAs) 
 
Medicaid SPAs 
 
Stand-alone COVID-19 Vaccine Counseling for Beneficiaries Eligible for EPSDT 
 
CMS released streamlined templates for states to utilize to make state plan changes related to 
COVID-19 vaccine administration, testing, and treatment under the ARP. 26   States must utilize 
these streamlined templates to comply with the required coverage and reimbursement for stand-
alone COVID-19 vaccine counseling for beneficiaries eligible for EPSDT that is discussed in 
this SHO Letter during the ARP coverage period.  States may seek waivers under section 1135 of 
the Act with respect to public notice timeframes, tribal consultation timeframes, and SPA 
effective dates when submitting SPAs using these templates, but only during the COVID-19 
PHE.  CMS cannot waive or modify statutory or regulatory requirements under section 1135 of 
the Act after the COVID-19 PHE ends.  Unlike the current disaster relief SPA templates, these 
new templates will allow states to extend their coverage after the end of the COVID-19 PHE 
through the end of the ARP coverage period without submitting a second SPA when the PHE 
ends.   
 
Stand-alone Vaccine Counseling for All Other Pediatric Vaccines for Beneficiaries Eligible for 
EPSDT  
 
All states should already be covering EPSDT, which requires states to cover health education 
and all medically necessary services that could be covered under the benefits listed in section 
1905(a) of the Act for eligible children under age 21. States in compliance with this requirement 
are not required to submit SPA coverage pages to specifically reflect that the required stand-
alone vaccine counseling is covered as part of the EPSDT benefit.  States that do not currently 
cover and reimburse for stand-alone vaccine counseling for all other pediatric vaccines covered 
under EPSDT for persons eligible for the EPSDT benefit will need to submit a reimbursement 
SPA.  A comprehensive description of the payment methodology for stand-alone vaccine 
counseling must be included in the reimbursement section of the Medicaid state plan.   
 
CHIP SPAs 
 
There is no SPA required to cover stand-alone vaccine counseling in CHIP.  Coverage and 
                                                            
26 https://www.medicaid.gov/resources-for-states/spa-and-1915-waiver-processing/medicaid-spa-processing-tools-
for-states/index.html 
 
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.  Page 11  State Health Official 
payment for stand-alone vaccine counseling in Medicaid-expansion CHIPs, including when 
covered for beneficiaries eligible for EPSDT, would be pursuant to the states Medicaid state 
plan.  CMS is available to provide technical assistance to states interested in covering stand-
alone vaccine counseling.  States should reach out to their CHIP project officer for more 
information. 
Coding 
States should alert Medicaid and CHIP providers to the American Medical Association (AMA) 
and AAP published codes for reporting stand-alone COVID-19 vaccine counseling.  The AMA 
publishes codes for all vaccines (including COVID-19 vaccines).27 The AAP also has 
information on billing codes that can be used for stand-alone COVID-19 vaccine counseling on 
its COVID-19 vaccine administration dedicated website.28 In addition, the AAP has information 
on billing codes for pediatric vaccines and vaccine counseling.   
To further assist states with coding for stand-alone vaccine counseling, CMS is developing new 
HCPCS codes that providers may use to bill for stand-alone vaccine counseling.  CMS 
anticipates providing more information about these codes soon.    
Conclusion 
CMS is eager to work with states on the implementation of Medicaid and CHIP coverage for 
stand-alone vaccine counseling to help increase vaccination rates for COVID-19 and other 
diseases.  CMS is committed to increasing vaccine confidence and the promotion of vaccinations 
for Medicaid and CHIP beneficiaries.  If you have any questions regarding this letter or would 
like to request technical assistance, please contact your respective CMS State Lead. 
Sincerely, 
Daniel Tsai 
Deputy Administrator and Director 
27 https://www.ama-assn.org/practice-management/cpt/covid-19-cpt-vaccine-and-immunization-codes and 
https://www.ama-assn.org/practice-management/cpt/covid-19-immunization-administration-and-em-visits.  
28 https://www.aap.org/en/pages/2019-novel-coronavirus-covid-19-infections/covid-19-vaccine-for-children/covid-
19-vaccine-administration-getting-paid/
The contents of this document do not have the force and effect of law and are not meant to bind the public in any 
way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public 
regarding existing requirements under the law.