New Pharmacy Partnership Insights for Section 202 Providers

Regulation | December 11, 2020 | by Linda Couch

Latest news on HUD Section 202 providers and the CDC's Pharmacy Partnership for Long Term Care

While states hold ultimate control over the order of which populations receive state vaccine allocations, the CDC’s Advisory Committee on Immunization Practices (ACIP), on December 1, voted to recommend the first “1a” tranche of distribution be to healthcare workers, nursing homes, assisted living communities, and residential care, including HUD Section 202 communities.

The CDC created the Pharmacy Partnership for Long Term Care (PPLTC) to help deliver the vaccine as effectively and quickly as possible to long term care providers, while easing the burden on state and local health departments, much of whose work will be focused on vaccinating the 1a group’s healthcare workers. LeadingAge is working to keep its Frequently Asked Questions on the vaccine and the updated.

Participation in the PPLTC is voluntary and long term care sites had to register to participate in the PPLTC by November 6. The PPLTC’s pharmacy partners, CVS and Walgreens, have begun to reach out to 1a long term care communities as vaccines shipments ready for shipment.

CVS and Walgreens, as the pharmacy partners in the PPLTC, will handle “end to end” vaccine distribution. However, some tasks will fall to the housing provider when vaccine distribution via the PPLTC is brought to a Section 202 community. A critical piece of the PPLTC’s work with a Section 202 community will be communication before any on-site vaccination clinic. While the pharmacies will handle all aspects of the vaccination, there are some issues and tasks that must be addressed and / or discussed with the pharmacy partner prior to the pharmacy coming in site.

These include:

Number of times the pharmacy partner will come to the community. As part of the PPLTC, CVS or Walgreens will come to a Section 202 community about three times, depending on the size of the housing community and other needs.

Communicating with residents. The CDC is developing a tool kit for PPLTC participants that will include sample letters to residents, flyers, conversation starters, and other information. On November 10, the CDC made available a training module toolkit for healthcare providers; housing providers may wish to glean information from this toolkit until the PPLTC toolkit is unveiled. What languages materials from CDC and Walgreens / CVS are offered in is an issue that should be discussed with the pharmacy partner.

Consent forms and insurance cards. Section 202 providers may be asked to distribute vaccine consent forms, which will be mailed to the housing community by the pharmacy partner, to residents. Consent forms are not required by the CDC but are being asked for by CVS and Walgreens. When these consent forms need to be filled out is a conversation for the housing provider and its pharmacy partner to have. The same is true for insurance cards. CVS or Walgreens may ask for photocopies of insurance cards, presenting a challenging task for housing providers. Again, this should be part of a pre-visit conversation. The pharmacy partners will bill administrative fees to Medicare, Medicaid, or private insurance companies, or will bill the HHS’s Health Resources & Services Administration’s uninsured fund. It’s important to know that no one can be turned away by the pharmacy partner and no resident or Section 202 provider will be billed for any costs whatsoever.

Space. The pharmacy partner and housing provider will need to talk about space considerations for the vaccinations, including if it’s necessary for the vaccinations to take place on a “door to door” basis because of the lack of appropriate space within the housing community.

Which Section 202 staff would be vaccinated? The ACIP recommendation is for both residents and staff of PPLTC participants to be vaccinated. Limited supply of the vaccine could result in the pre- conversations between CVS/Walgreens and a Section 202 site considering which Section 202 staff should receive the vaccine. Certainly, any staff with any direct contact with residents should, including Service Coordinators.

All Independent Living is not included in the ACIP’s 1a group. LeadingAge strongly advocated for all aging services providers to be included in the ACIP’s 1a recommendation. Ultimately, ACIP’s 1a recommendation included HUD Section 202 housing providers because many residents would be in private assisted living if they could afford it and are included from a health equity standpoint, even if every resident does not meet strict criteria for assisted living.

Is anyone mandating the vaccine? The federal government is prohibited from mandating any vaccine under an Emergency Use Authorization, including COVID-19 vaccines. States and private organizations could choose to mandate, but that would bring with it myriad issues that should be considered. Some of these are spelled out in LeadingAge’s FAQ.

The CVS/Omnicare and Walgreens/PharMerica have their own PPLTC websites, as does the CDC.

All of these are evolving issues and the information provided in this article will change as the PPLTC moves forward. Housing stakeholders are encouraged to keep up with information as it becomes available, including through the LeadingAge website.