2025 COVID Vaccine Administration Update: Medicare and Commercial

An October 2025 policy change by the Centers for Medicare and Medicaid Services (CMS) has resulted in denials for the administration of the COVID vaccine for both Medicare and Commercial plans … whenever a patient has received a COVID vaccine AND any other vaccine at a single appointment.

Medicare – Policy Reversed

CMS recently rescinded the rule change for Medicare members only. The agency will reprocess impacted COVID vaccine administration claims with dates of service between July 1 and Oct. 15. Providers may also choose to use the MAC appeals process if they don’t wish to wait for the automatic adjustment.

Commercial – Policy Still in Effect; Option for Reimbursement

The policy change for COVID vaccine administration, however, remains in place for Commercial members.

IMPORTANT: Providers can continue to receive payment for COVID-19 vaccine administration for Commercial members, even when co-administered with other vaccines, by correctly applying the appropriate National Correct Coding Initiative (NCCI) modifier to the claim.

Background

On Oct. 14, 2025, CMS published NCCI edits that denied payment for the administration of the COVID vaccine when another vaccination was given at the same appointment. This change affected both Medicare Advantage (MA) and Commercial members.

While providers were being paid for the COVID vaccine itself, they were not being reimbursed for the administration of the vaccine, which was a change from previous CMS policy.

To avoid payment denials for the administration portion of the COVID vaccine, it is essential to utilize the correct NCCI modifier when submitting claims.