COVID-19 Frequently Asked Questions (FAQs)

As indicated by the CDC, a limited supply of COVID-19 vaccine is available in the United States, but the supply will increase in the weeks and months to come.

The goal is for everyone to be able to get vaccinated against COVID-19 as soon as large enough quantities are available. Once vaccine is widely available, the U.S. COVID-19 Vaccination Program plan is to have several thousand vaccination providers offering COVID-19 vaccines in doctors’ offices, retail pharmacies, hospitals, and Federally Qualified Health Centers.

More information is available at Vaccines.gov, which will continue to be updated as vaccine recommendations and supply levels change. HRSA will update related information accordingly.

(Added: 1/11/2021)

In accordance with the CDC's U.S. COVID-19 Vaccination Program, in order to receive and administer COVID-19 vaccine, constituent products, and ancillary supplies, vaccination provider facilities/organizations must enroll in the U.S. COVID-19 Vaccination Program coordinated through their jurisdiction's immunization program. Enrolled COVID-19 vaccination providers must be credentialed/licensed in the jurisdiction where vaccination takes place, and they must sign and agree to the conditions in the CDC COVID-19 Vaccination Program Provider Agreement.

Health centers may contact the state and/or local immunization program manager in their jurisdiction for information on how to become a COVID-19 vaccine provider. A list of immunization program managers is available through the Association of Immunization Managers .

Starting the week of February 15, 2021, HRSA is partnering with the CDC to directly allocate a limited supply of COVID-19 vaccine to select health centers through the Health Center COVID-19 Vaccine Program. The program will begin incrementally at select HRSA-funded health centers that specialize in caring for particularly hard-to-reach and disproportionately affected populations, including people experiencing homelessness, agricultural workers, residents of public housing, and those with limited English proficiency. As supply increases, HRSA and the CDC will support vaccination in additional targeted health centers. More information is available in the Health Center COVID-19 Vaccine Program section of this FAQ.

(Updated: 2/19/2021)

The CDC maintains information and exercises oversight regarding the U.S. COVID-19 Vaccination Program. As indicated in CDC’s COVID-19 Vaccination Program Provider Enrollment: Guidance for Providers, health care providers that enroll as participating providers in the U.S. COVID-19 Vaccination Program must sign the CDC COVID-19 Vaccination Provider Agreement, which includes various requirements specific to the program. Of note, participating providers are required under the provider agreement not to seek payment from patients who receive COVID-19 vaccine doses purchased by the U.S. government. However, enrolled providers may charge a fee for the administration of the vaccine, and therefore may seek reimbursement for the administration of the vaccine from the patient’s public or private insurance company, or, for uninsured patients, from the COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program.

Health centers may enroll to be providers in the U.S. COVID-19 Vaccination Program and provide COVID-19 vaccinations within their Health Center Program scope of project. Consistent with section 330 requirements for in scope services, if health centers participate with the U.S. COVID-19 Vaccination Program, they should continue to make every reasonable effort to collect appropriate reimbursement for COVID-19 vaccine administration costs, including billing Medicare, Medicaid, CHIP, and other public and private insurance or assistance programs, as applicable. However, health centers that participate in the U.S. COVID-19 Vaccination Program, consistent with the terms and conditions of the program, cannot charge vaccine recipients, both uninsured and those with copays, to whom they provide in-scope COVID-19 vaccinations for unreimbursed vaccine administration costs.

(Added: 1/26/2021)

The Centers for Medicare and Medicaid Services (CMS) has information regarding provider reimbursement for the administration of COVID-19 vaccines.

(Added: 1/4/2021)

Health centers have discretion, consistent with applicable law, to determine which practitioners are qualified to administer vaccines. In addition, health centers that have enrolled in the CDC's U.S. COVID-19 Vaccination Program also must comply with all of the requirements of the CDC COVID-19 Vaccination Program Provider Agreement. The provider agreement includes provisions relating to completion of training, reporting and managing vaccine inventory, storing and handling vaccine, reporting of adverse events, and reporting of data on doses administered.

To further clarify, health centers that provide COVID-19 vaccinations must:

• Familiarize themselves and comply with state and federal requirements relating to COVID-19 vaccination, including provider qualifications to administer COVID-19 vaccinations;
• Comply with the health center's own credentialing and privileging procedures regarding provider qualifications to administer COVID-19 vaccinations; and
• Document in the health center's credentialing files compliance with applicable provider qualification standards/requirements for administering COVID-19 vaccinations.

Health centers should be aware that the HHS Secretary has issued a declaration with amendments under the Public Readiness and Emergency Preparedness (PREP) Act relating to COVID-19 countermeasures, including authorized COVID-19 vaccines.

• The declaration authorizes certain health care professionals who may not otherwise be permitted to administer COVID-19 vaccines to do so. These include pharmacists, pharmacy interns, and pharmacy technicians; health care professionals who are licensed in another state; and certain physicians, advanced practice registered nurses, registered nurses, or practical nurses whose license or certification has lapsed within the last five years, when they meet specified criteria and conditions.
• The declaration also provides immunity from claims to covered person (as defined in the declaration) and individuals involved in the development, manufacture, testing, distribution, administration, and use of covered countermeasures for claims of loss caused, arising out of, relating to, or resulting from administration or use of the covered countermeasures when the conditions in the declaration are met.

For information regarding FTCA coverage for deemed health centers, see the FTCA Health Center Policy Manual (PDF - 406 KB); the March 27, 2020 Determination of Coverage for COVID-19-Related Activities by Health Center Providers (PDF - 35 KB); and other questions in this FAQ.

(Updated: 2/19/2021)

Health centers that have been deemed as federal employees through the Health Center FTCA Program are eligible for liability protection for grant-supported activities by “covered providers” and deemed volunteer health professionals. Deemed health centers that receive a claim or a legal summons and complaint involving the administration of a vaccination should promptly provide such documentation to the HHS OGC General Law Division, as described in the Health Center FTCA Policy Manual (PDF - 358 KB), Section II. Claims and Lawsuits.

Pursuant to the Public Readiness and Emergency Preparedness (PREP) Act, the Secretary of HHS has also issued a declaration (and amendments) concerning medical countermeasures against COVID-19, which declared that COVID-19 vaccines are also covered countermeasures for the purposes of liability protection under the PREP Act. If all requirements set forth in the Secretary’s declaration are met, a covered person is immune from liability except for “willful misconduct” with respect to all claims for loss caused by, arising out of, relating to, or resulting from the manufacture, testing, development, distribution, administration, and use of a COVID-19 vaccine.

An individual who sustains a covered serious physical injury or death as a direct result of the administration or use of a covered countermeasure (or estates and survivors of such individual) may be eligible for certain benefits under the Countermeasures Injury Compensation Program (CICP), which is administered by HRSA. Information about the CICP and filing a claim are available toll-free at 1-855-266-2427, or at the CICP website.

(Added: 1/5/2021)

Yes. Health centers may participate in community vaccination campaigns conducted in coordination with state, territorial, or local responses to the COVID-19 public health emergency, within their scope of project, if the health center is performing these activities on behalf of the health center.

Health center providers would demonstrate that they are acting on behalf of the health center when they provide in-scope services if they clearly identify themselves as health center staff, the health center compensates the work of health center providers, the health center maintains the vaccination records, and the health center bills for any administration fee associated with vaccination. Health centers should maintain documentation that identifies the date, place, and circumstances during which they provide such services.

Providing vaccinations on behalf of a third-party entity, for example as an independent contractor of a third party entity, would constitute another line of business, and would not be an in-scope activity. For more information on assessing whether services or activities are performed on behalf of the health center, review the Considerations for Health Center Scope of Project During the COVID-19 Public Health Emergency.

Additional practice considerations pertinent to in-scope activities include the following:

• If health centers partner with other organizations conducting community-based immunization programs, they should make arrangements with those organizations, as necessary, to obtain timely documentation of immunizations administered by health center providers.
• Health centers that participate in the CDC COVID-19 Vaccination Program must follow all COVID-19 vaccine and administration reporting requirements specified in the CDC COVID-19 Vaccination Program Provider Agreement.

Health centers without “Immunizations” listed as an activity on Form 5C: Other Activities/Locations (PDF - 103 KB) should, in advance of participating, submit a brief Scope Adjustment request via EHBs to add this activity to their scope of project. When completing the Form 5C Scope Adjustment request, select “Immunizations” as the “Activity”; under “Frequency” state “as needed”; and under “Activity Location” state “various locations within the community as appropriate to respond to vaccination needs.” Once approved by HRSA, this activity will be documented as in-scope on the health center’s Form 5C.

For information about liability protections relating to health center providers providing COVID-19 vaccines, please see the question “What liability protections apply to health center providers when an individual who receives a vaccine has an adverse reaction?” in this FAQ.

(Added: 2/1/2021)

Yes. The Health Center Program views providing COVID-19 vaccinations as an element of in-scope general primary care and immunization services, as reflected on Form 5A: Services Provided. Health centers may administer COVID-19 vaccinations to health center patients and to individuals who are not health center patients within their scope of project both at the health center and at locations within the community that are not a health center’s service sites, as documented on Form 5B or 5C as appropriate. Health centers that provide such services should review additional information on Considerations for Health Center Scope of Project During the COVID-19 Public Health Emergency.

As with all in-scope services, health centers should maintain records of immunizations they provide consistent with applicable standards of practice. Health centers that partner with other organizations conducting community-based immunization programs should make arrangements with those organizations, as necessary, to obtain timely documentation of immunizations administered by health center providers. If a health center’s providers deliver health services on behalf of a third party entity, these activities would constitute another line of business outside the scope of the Health Center Program project.

For additional resources, health centers may wish to review CDC Guidance for Planning Vaccination Clinics Held at Satellite, Temporary, or Off-Site Locations.

Health centers may contact the state and/or local immunization program manager in their jurisdiction for more information about COVID-19 vaccines. A list of immunization program managers is available through the Association of Immunization Managers .

(Added: 1/11/2021)

Sites recorded on Form 5B: Service Sites must be locations that meet the definition of a service site in PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF - 224 KB). Specifically, these are locations where all of the following conditions are met:

• Health center encounters are generated by documenting in the patients’ records face-to-face contacts between patients and providers;
• Providers exercise independent judgment in the provision of services to the patient;
• Services are provided directly by or on behalf of the grantee, whose governing board retains control and authority over the provision of the services at the location; and
• Services are provided on a regularly scheduled basis (e.g., daily, weekly, first Thursday of every month). However, there is no minimum number of hours per week that services must be available at an individual site.

To determine whether locations where COVID-19 vaccination is being provided should be listed on Form 5B: Service Sites, a health center must determine if the location meets all site criteria above.

If a health center, on its own behalf, plans to provide vaccinations to individuals within the community at a location that is not an approved service site, such activity may be within the scope of project and documented on Form 5C: Other Activities/Locations. As described in PIN 2008-01 linked below, the criteria for activities to be included on Form 5C are those that (1) do not meet the definition of a service site, (2) are conducted on an irregular timeframe/schedule, and (3) offer a limited activity from within the full complement of health center activities included within the scope of project. However, providing vaccinations on behalf of a third-party entity constitutes another line of business, rather than an in-scope activity. Activities on behalf of third-party entities would not be reflected on Form 5C: Other Activities/Locations.

View additional information on Considerations for Health Center Scope of Project During the COVID-19 Public Health Emergency.

View PIN 2008-01: Defining Scope of Project and Policy for Requesting Changes (PDF - 224 KB), Section III.B.(g), for information about recording activities on Form 5C: Other Activities/Locations.

(Added: 1/11/2021)

If a health center does not have “Immunizations” listed as an activity on its Form 5C: Other Activities/Locations (PDF - 114 KB), it must submit a brief Scope Adjustment request via EHBs to add this activity to its scope of project. When completing the Form 5C Scope Adjustment, select “Immunizations” as the “Activity”; under “Frequency” state “as needed”; and under “Activity Location” state “various locations within the community as appropriate to respond to vaccination needs.” Once approved by HRSA, this activity will be documented as in-scope on the health center’s Form 5C.

(Added: 1/21/2021)

Health centers provide COVID-19 vaccinations to established patients and other individuals who present for such services (i.e., new patients) and meet criteria for vaccination, regardless of an individual’s ability to pay. Health centers should contact the state and/or local immunization program manager in their jurisdiction for more information on the criteria or priority guidelines for the provision of COVID-19 vaccines. A list of immunization program managers is available through the Association of Immunization Managers .

If a health center does not have sufficient capacity to vaccinate individuals beyond its established patient population (e.g., due to limited Personal Protective Equipment (PPE), supplies, or staff capacity), the health center should refer patients to other appropriate providers. For PPE and supply needs, health centers should communicate and coordinate with state, tribal, and local health departments and Primary Care Associations in their state, in addition to reporting these needs to HRSA through the weekly HRSA Health Center COVID-19 Survey.

Health centers that participate in the HRSA Health Center COVID-19 Vaccine Program should consult the conditions for participation in the program for information regarding vaccination criteria and coordination with jurisdictions.

(Added: 2/19/2021)