The Vermont Vaccine Purchasing Program (VVPP) operates to ensure that all Vermonters have access to immunizations recommended for children and adults. Authorized by 18 V.S.A. § 1130 and launched on April 1, 2011, the program establishes an insurer-funded vaccine purchasing pool that enables the Vermont Department of Health (VDH) to purchase pediatric and adult vaccines at the lowest possible price and to distribute them to providers free of charge. The program serves two main goals: to lower health care costs and to improve Vermonters’ health by raising immunization rates.
These advisory FAQs offer guidance about the program to payers and providers. The Vermont Department of Health invites anyone having suggestions or additional questions about these advisory FAQs to direct inquiries to info@VTvaccine.org.
The advisory FAQs are divided into five broad categories:
1. “A” means questions related to Assessments.
2. “C” means questions related to Covered Lives.
3. “G” means questions related to Government Programs.
4. “P” means questions related to Providers.
5. “V” means questions related to Vaccines.
A1. Why did the Vermont legislature form the Vermont Vaccine Purchasing Program (VVPP)?
VVPP was formed to fund and manage Vermont’s universal vaccine purchasing program. This program enables Vermont to purchase vaccines for the state’s entire population and distribute them to health care providers free of charge. In states without such universal programs, providers must purchase vaccines with money out of their own pockets, then await reimbursement from insurance companies
The program also saves money. By purchasing vaccines in bulk at federal contract rates, Vermont qualifies for the largest discount available from the pharmaceutical industry. VVPP funds vaccine purchases with assessments collected from assessed entities.
A2. Are insurance carriers the only ones paying for vaccines administered in Vermont?
No. Self-insured employers, TPAs, HMOs, and other payers are also subject to assessment. These payers fund the purchase of vaccines for all privately insured children and adults. The federal Vaccines for Children (VFC) program pays for vaccines for all VFC eligible children less than 19 years of age, including Alaska Natives, American Indians, and Medicaid-insured, uninsured, and underinsured children served at FQHCs and RHCs. Federal 317 funding is used to pay for the cost of vaccines for uninsured adults.
A3. What does “Assessed Entity” mean?
“Assessed Entity” means any health insurance company, nonprofit hospital and medical service corporation, managed care organizations, and, to the extent permitted under federal law, any administrator of an insured, self-insured, or publicly funded health care benefit plan offered by public and private entities. But, it does not apply to insurers providing coverage only for a specific disease or other limited benefit coverage.
A4. Must both the employer and the insurer or TPA administering the plan pay the assessment for a given covered life?
No. VVPP’s plan of operation seeks to avoid double counting any covered life. Generally speaking, the entity responsible for paying for the vaccine administration is also the entity responsible for paying the assessment. However, to avoid double counting, and to accommodate the needs of specialty plans and private contractual arrangements, VVPP will allow another entity to pay the assessment if the agreement between entities is in writing and the existence of the agreement is stated in the “Additional Questions” section of the assessment system. It is recommended that agreements specifically include an indemnification of the entity not paying. The agreement must be made available for review if there is an audit in the future. VVPP does not need to see the agreement and does not have any advance approval role as to the agreement or its content.
A5. Must ERISA plans pay the assessment?
Yes. Any health benefit plan that covers child or adult residents of Vermont is required to participate. The VVPP legislation encompasses plans that offer Administrative Services Only (ASO) for ERISA employers. It also includes traditional Third-Party Administrators (TPAs).
A6. Are any plans excused from paying assessments?
Yes. The following plans are excused from paying assessments: Medicare supplement plans, college plans, pharmacy benefit plans, ASOs and TPAs for behavioral and dental health plans, and plans that do not include immunization services. If you are unsure whether your plan is required to pay assessments, please email VVPP at info@VTvaccine.org or call 1-855-543-7829.
Please note that plans excused from the assessment must self-certify that they have no business to which a vaccine assessment properly should be applied. If a plan’s status changes, it must notify VVPP and begin paying assessments.
A7. How are an entity’s assessments determined?
Each entity’s assessment is based on the entity’s total number of child covered lives and adult covered lives in the months during the previous quarter, multiplied by the respective VVPP assessment rates for children and adults. Payers are required to accurately report child and adult covered lives each quarter. VVPP’s automated web-based assessment system then calculates the assessment amounts owed.
A8. What are the VVPP assessment rates for child and adult covered lives?
Information on the assessment rates for child and adult covered lives is posted under the “FOR PAYERS” tab. Assessments are calculated based on estimated vaccine costs, program expenses, and the total number of covered lives reported to VVPP. The assessments are intended to cover the costs of the program for the calendar year, with some modest reserves. The rates are also programmed into VVPP’s self-reporting assessment system so that the system will apply the correct rate each quarter and calculate the amount owed by each payer. The rate is set each year by the Commissioner of Health, after considering the recommendations of the Immunization Funding Advisory Committee.
A11. When are assessment payments due?
Quarterly assessments are due forty-five days after the close of each quarter. VVPP operates on a calendar year running from January 1 to December 31. Typically, this means that reports and payments will be due on February 15, May 15, August 15, and November 15. Quarterly payments are based on the number of covered lives an entity reports for the three months in each respective quarter.
A12. What if VVPP collects too little?
If VVPP’s estimates produce funds which are too low to meet the needed vaccine costs, VVPP may issue a supplemental assessment. VVPP’s reserve methodology has been designed so that no supplemental assessment should be needed, but that cannot be guaranteed in advance.
A22. How do I submit my payment?
When you file your report in the assessment system on this website, the program will generate a “VVPP Remittance Form” that you can print and save. This form will contain a unique reference number. You must include this reference number with your payment. The form will also include detailed instructions for submitting your payment by ACH transfer, which is the preferred payment method.
A23. Am I required to pay by ACH transfer?
No. While the Vermont Department of Health prefers that you send your payment by ACH transfer, they also allow you to mail a check. Checks should be made payable to “Vermont Vaccine Purchasing Program” and should be mailed to:
Vermont Vaccine Purchasing Program
c/o Immunization Program Ste. 305
Vermont Department of Health
PO Box 70
Burlington, VT 05402
C2. What are “adult covered lives”?
“Adult covered lives” are Vermont residents who are age 19 to 64 and are covered under a health benefit plan provided or administered by an Assessed Entity.
For reports filed for reporting periods after January 1, 2016, only individuals up to age 64 are included in the program. This is a change from the prior procedure. This change will apply to the reports that are due on May 15, 2016. For reports filed for time periods prior to January 1, 2016, adult covered lives included all individuals age 19 and older, without any age limit.
C3. What are “child covered lives”?
“Child covered lives” are Vermont residents who are less than 19 years who are covered under a health benefit plan provided or administered by an Assessed Entity.
C5. What if a child of a Vermont primary insured attends school out of state—is that life counted?
Generally, yes. However, if the plan definitively knows (1) the child’s PCP is out of state, (2) the child is out of state year round, AND (3) the plan also adopts a practice of counting students attending schools in Vermont whose parents reside out of state, that covered life should not be counted. Accordingly, the default rule for college-age children, where a specific year-round residence address is unknown, should be to count the child as a resident of the state of the primary insured.
C6. Must an entity file reports even if it does not provide medical benefits and therefore has zero covered lives?
Yes, but the entity may be eligible to file an Annual or Permanent Zero Covered Lives Report instead of the typical quarterly reports. Please note that if an entity has zero covered lives for one quarter only, then it should file a normal quarterly report with “0” values.
If, however, an entity does not administer medical benefits and therefore has zero covered lives, it should file one of two types of Zero Covered Lives Reports. For example, this type of report would be appropriate for entities such as those administering eye care or dental benefit only plans. If the entity has zero covered lives and will continue to have zero covered lives for the balance of the year, then it should file an Annual Zero Covered Lives Report during the first quarter of the calendar year. No other report will be due until the first quarter of the following calendar year. If the entity has zero covered lives and expects to never have covered lives, it should file a Permanent Zero Covered Lives Report to eliminate the need for further compliance follow up. A guide to Zero Covered Lives Reports is available in the “Filing Guides” section under the “FOR PAYERS” tab.
P2. What are the benefits to my practice if we enroll in the VFC and/or VFA program?
Vermont is a universal vaccine purchase state, where the state Immunization Program purchases vaccines from the CDC federal contract at no cost to providers, for use by all children and adults. Patients may still be charged an immunization administration fee. This is intended to assist you in providing comprehensive preventive care and to allow for fewer missed opportunities for immunization.
P5. How will this program affect patients?
Patients will not be charged for the cost of the vaccine. This program ensures that proper funding is available to continue to distribute vaccines at no charge to the patient. Some patients may still be charged an immunization administration fee.
P7. Should providers bill $0.00 or $0.01 for state-supplied vaccines?
VDH has no preference regarding whether state-supplied vaccines are billed with a charge of $0.00 or $0.01, but VDH is committed to working with all interested parties to establish procedures that support the providers and insurers who participate in the program. Please contact your billing servicer for specific instructions about its billing procedures. Generally, servicers require providers to use the Health Care Procedure Coding Systems (HCPCS) National Level II Medicare Code Modifier (SL: State supplied vaccine) when billing for state-supplied vaccine.
V1. Does VVPP set vaccine policy?
Neither VVPP nor KidsVax® takes a position for or against the administration of any particular vaccine to any specified individual. The VVPP will generally fund the vaccines shown on the Vermont Recommended Immunization Schedule.
V4. Does this program establish a vaccine mandate?
No. VVPP does not set vaccine policy or create vaccine laws. It facilitates the state’s universal purchase of vaccines by collecting assessments from insurers, third-party administrators, and other payers.
V5. What is the Immunization Registry?
The Vermont Immunization Registry (IMR) is a confidential, computerized system for maintaining immunization records. It tracks the dates of immunizations given, prints reports for parents/schools, and provides guidance for timing of vaccine administration.
V6. How does VVPP impact my taxes?
VVPP is not funded by taxpayers. VVPP collects the costs of vaccines and program expenses from insurers, third-party administrators, and other payers who are already obligated to pay health care costs for their beneficiaries. These funds are paid directly to the state so the state can purchase vaccines at federal contract rates. This lowers the cost to insurers of funding immunization services.
These FAQs were last updated on January 2, 2016. (FAQ C2 updated).