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)?
A2. Are insurance carriers the only ones paying for vaccines administered in Vermont?
A3. What does “Assessed Entity” mean?
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?
A7. How are an entity’s assessments determined?
A8. What are the VVPP assessment rates for child and adult covered lives?
A9. What method will be used to: a) determine the number of children and adults with private insurance and b) determine the VVPP program costs that will be factored into the assessment?
a) The total number of children and adults with private insurance will be determined based on the most recent data available through the assessment system when the rate is set.
b) The program costs include costs incurred by the Vermont Department of Health in administering the program, as well as the cost of KidsVax® services such as the VVPP website creation and assessment administration.
A10. Where can I find more details about the VVPP assessment rate calculation?
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.
A13. What if VVPP collects too much?
A14. What if a beneficiary gets a vaccine in a neighboring state—can the payer get a discount
A15. Are payments made by assessment payers accountable as medical expenses?
A16. Does the Patient Protection and Affordable Care Act (ACA) preempt any provisions of the VVPP?
A17. Where do I go to complete the online assessment?
A18. Are there any tutorials on the use of this system?
A19. What if I have registered in the assessment system, but I need to change some of my information?
Simply log back in to your account and made any changes needed. This should not create any problems for you or the system.
A20. If I make a mistake in my report, how can I correct it?
A21. I accidentally overpaid. Can I be reimbursed?
A22. How do I submit my payment?
A23. Am I required to pay by ACH transfer?
A24. What if I submit a late report or payment?
A25. When is my remittance considered paid?
A26. How do I create a Password for the Assessment System on this Site?
A27. What should I do if my company has created a password for the assessment system on this website, but I no longer have it?
A28. Are payers double paying for a vaccine when a private provider administers a vaccine that was not purchased through the state system?
C1. Must entities report only child covered lives, or should adult covered lives be included as well?
C2. What are “adult covered lives”?
C3. What are “child covered lives”?
C4. What if I do not know the specific address where a child resides, and am unable, therefore, to determine with certainty whether he or she is a Vermont resident?
Plans are permitted to use a commercially reasonable methodology to estimate the number of child covered lives. For example, some plans may want to use the address of the primary insured to determine the residence of the child. So long as a methodology is uniformly used in a manner which does not bias the report towards a lower child covered lives number, such a reasonable estimate is acceptable. Whenever an estimate is used, please include a brief description of the methodology in the “Additional Questions” section of the self-reporting system.
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.
C7. If an entity files a Permanant Zero Covered Lives Report, but it later has covered lives, what should it do?
C8. If my company has filed an Annual Zero Covered Lives Report, when should we file our next report?
G1. Has VVPP changed anything for the federally-funded Vaccines for Children (VFC) program or state-sponsored medical plans?
G2. Do providers still need to screen for VFC eligibility?
P1. Does this program affect how providers receive vaccine?
P2. What are the benefits to my practice if we enroll in the VFC and/or VFA program?
P3. Can VDH require all providers to enroll in the VFC and/or VFA program?
P4. Can VDH provide a list of participating providers in “real time”?
P5. How will this program affect patients?
P6. What if my office no longer wants to participate in the VFC and/or VFA program and wants to privately purchase and bill for vaccines?
P7. Should providers bill $0.00 or $0.01 for state-supplied vaccines?
V1. Does VVPP set vaccine policy?
V2. What vaccines are covered by VVPP?
V3. Is the cost of seasonal flu vaccine included in the vaccine cost estimates?
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?
V6. How does VVPP impact my taxes?
These FAQs were last updated on January 2, 2016. (FAQ C2 updated).