Vaccines for Children Program (VFC) For State Immunization Projects
General Questions about State Immunization Projects
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What is the process for including a new vaccine in the VFC program and how are immunization programs informed about the changes? Do CDC and grantees have any federal requirement to implement ACIP-recommended vaccines? What is the 90-day VFC Medicaid rule? Is Medicaid federally mandated to cover ACIP’s VFC-recommended vaccines for the Medicaid population? Can a state require Medicaid providers to become VFC-program registered providers in order to ensure that Medicaid-eligible children receive vaccine under the VFC program? How long should VFC records be retained by a provider? Is a faxed signature on the VFC Provider Enrollment form adequate for our records? Title X Documents

1. What is the process for including a new vaccine in the VFC program and how are immunization programs informed about the changes?
   
   The Advisory Committee on Immunization Practices (ACIP) has the advisory role to determine what vaccines should be recommended for administration to children, adolescents, and adults in the U.S. and the operational role to approve which vaccines should be available through the VFC program. The ACIP meets three times a year, and during these meetings newly licensed vaccines may be discussed and recommended for use. Once a vaccine is recommended by ACIP, a vote is taken about whether or not to include the new vaccine in the VFC program through consideration of a VFC resolution. VFC resolutions are specific to each vaccine and include who is eligible to receive the vaccine, the vaccination schedule, and precautions or contraindications to the vaccine. Once the VFC resolution is approved, CDC must negotiate a contract for the vaccine to make it available under the VFC program. VFC resolutions are posted on CDC’s website.

2. Do CDC and grantees have any federal requirement to implement ACIP-recommended vaccines?
   
   CDC and immunization programs that receive VFC funds are required to implement ACIP-recommended vaccines for which there are VFC resolutions and for which federal contracts have been established to purchase these vaccines. When using 317, state and local funds for immunizations, implementation of all ACIP recommendations is not required.

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VFC and Medicaid

**Note: Included are several general questions related to VFC and Medicaid. Additional questions relevant to Medicaid are included in other sections of the document as well.

3. What is the 90-day VFC Medicaid rule?
   

   Section 13631(g) of the Omnibus Budget Reconciliation Act of 1993 (OBRA ’93) provided that vaccination services covered under the Early and Periodic Screening Diagnostic and Treatment (EPSDT) benefit for Medicaid-eligible children will follow the ACIP-established VFC schedule beginning 90 days after establishment of the schedule. CMS considers the 90-day clock to begin on the publication date in the MMWR of ACIP general recommendations for use of a VFC vaccine. Check with the state Medicaid program or CMS for more information regarding theeffective date of a new VFC vaccine requirement for EPSDT children and payment of administration fees for such Medicaid children.
   
   Please Note : The 90-day rule does not apply to other categories of federally vaccine-eligible VFC children (i.e., uninsured, underinsured and American Indian/Alaska Natives). The VFC requirement for non-Medicaid federally vaccine-eligible children is effective on the effective date noted in the ACIP VFC resolution for a particular VFC vaccine or the date vaccine is first available through a CDC VFC contract, whichever is later.

4. Is Medicaid federally mandated to cover ACIP’s VFC-recommended vaccines for the Medicaid population?
   
   Yes, all of ACIP’s VFC-recommended vaccines are part of the EPSDT benefit package for Medicaid children under age 21. Immunizations through age 18 years are covered by the VFC program. Children 19 years through 20 years are covered by Medicaid program funds.

5. Can a state require Medicaid providers to become VFC-program registered providers in order to ensure that Medicaid-eligible children receive vaccine under the VFC program?
   
   Yes, the state Medicaid agency does have the option to require participation in the VFC Program.

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6. How long should VFC records be retained by a provider?
   
   At minimum, the VFC program provider records must be kept for a period of three (3) years after service to the patient has been completed unless state law/policy establishes a longer archival period. Each state may have different rules regarding the retention of medical records, especially medical records of minor children.  The two key agencies to check with regarding record retention rules are the state licensing board and/or the Secretary of State.

VFC and Record Keeping

7. Is a faxed signature on the VFC Provider Enrollment form adequate for our records?
   
   If a VFC staff member is unable to obtain the provider’s signature on the enrollment forms during the initial VFC enrollment site visit, then a signature on the faxed copy of the provider enrollment forms is acceptable for the VFC program records.

Title X Documents

• Patient Eligibility Screening Record Vaccines for Children Program for Title X Programs (.doc)

• Title X Unaccompanied Minor without Insurance Information VFC Vaccine log (.doc)

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This page last modified on June 4, 2007