ASHP Applauds CMS Requirement for States to Enroll Pharmacists as Medicaid Providers, Issues Medicaid and CHIP Vaccine Counseling Codes

Published: June 9, 2022
ASHP Press Release

On June 8, 2022, the Centers for Medicare & Medicaid Services (CMS) released stand-alone Medicaid & Children’s Health Insurance Program (CHIP) vaccine counseling Healthcare Common Procedure Coding System (HCPS) codes for counseling provided to Medicaid and CHIP beneficiaries who are eligible both for Early and Periodic Screening, Diagnostic and Treatment (EPSDT) provisions, and the COVID-19 vaccination coverage required under the American Rescue Plan. These codes can be used for stand-alone vaccine counseling provided in-person and/or via telehealth.

“ASHP applauds CMS’ actions to expand access to vaccination counseling for Medicaid and CHIP beneficiaries by requiring all states to enroll pharmacists as Medicaid providers,” said Tom Kraus, ASHP vice president of government relations. “Now it's time for the states to step up and rapidly enroll pharmacists, so their residents have access to these important services.”

In a memo sent to state health officials, CMS noted, “State Medicaid programs are expected to give all provider types authorized to administer COVID-19 and childhood vaccinations under the Department of Health and Human Services (HHS) COVID-19 Public Readiness and Emergency Preparedness (PREP) Act declaration an opportunity to enroll as Medicaid providers and receive Medicaid payment—not 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.” The memo further indicates, “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.”

Pharmacists are authorized under the PREP Act to provide COVID-19 and childhood vaccinations. CMS’ memo to states appears to include pharmacists among the provider types that states must allow to enroll as providers eligible to receive Medicaid payments in all 50 states.


About ASHP

ASHP is the collective voice of pharmacists who serve as patient care providers in hospitals, health systems, ambulatory clinics, and other healthcare settings spanning the full spectrum of medication use. The organization’s more than 60,000 members include pharmacists, student pharmacists, and pharmacy technicians. For 80 years, ASHP has been at the forefront of efforts to improve medication use and enhance patient safety. For more information about the wide array of ASHP activities and the many ways in which pharmacists advance healthcare, visit ASHP’s website,, or its consumer website,


Posted June 9, 2022

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