COVID-19 Frequently Asked Questions (FAQs)

Patients can contact their local health center to find out about availability of COVID-19 vaccine appointments. To find your local health center, please use HRSA's Find a Health Center tool.

In addition, states or territories can provide information on other vaccine locations. More information is available from the CDC.

(Updated: 2/25/2021)

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 .

To ensure our nation's underserved communities and those disproportionately affected by COVID-19 are equitably vaccinated against COVID-19, HRSA and CDC launched the Health Center COVID-19 Vaccine Program. As of April 7, 2021, HRSA and CDC have invited all HRSA-funded health centers and Health Center Program look-alikes to access vaccines through the program, if they wish to join and have the necessary capabilities. More information is available in the Health Center COVID-19 Vaccine Program section of this FAQ webpage.

(Updated: 4/22/2021)

COVID-19 vaccination providers, including participating health centers, are required to report information on vaccine supply, vaccine administration, and vaccine adverse events. Reporting this information is critical to help stop the COVID-19 pandemic.

Health centers that provide vaccines must comply with the CDC COVID-19 Vaccination Program provider requirements regarding data and reporting:

• COVID-19 vaccination providers must document vaccine administration in their medical record systems within 24 hours of administration, and use their best efforts to report administration data to the relevant system for the jurisdiction (i.e., Immunization Information Systems (IIS)) as soon as practicable and no later than 72 hours after administration. For information on the required vaccine administration data reporting elements, please see the FAQs for Private and Public Healthcare Providers About Implementing the CDC COVID-19 Vaccination Program in Provider Practices.
• All COVID-19 vaccination providers enrolled in jurisdictional immunization programs must report COVID-19 vaccine inventory daily into Vaccines.gov for allocations from jurisdictions. (Note: The Health Center COVID-19 Vaccine Program allocation should NOT be reported in Vaccines.gov.) In some jurisdictions, providers may report vaccine inventory to the jurisdiction’s IIS for the jurisdiction to upload into Vaccines.gov. If you have questions about the process for your jurisdiction, please contact your jurisdiction’s immunization program. For a list of Immunization Program Managers, please visit the Association of Immunization Managers website.
• All health centers that participate in the Health Center COVID-19 Vaccine Program must report COVID-19 vaccine inventory daily into the VTrckS Provider Order Portal (VPoP) for the HRSA allocation ONLY. (Note: The jurisdictional-supplied allocation should NOT be reported in VPoP.) If you have questions about the process for the Health Center COVID-19 Vaccine Program, please submit them through Health Center Program Support online or call 877-464-4772, option 2, 8 a.m. to 8 p.m. ET, Monday-Friday (except federal holidays).
• Health care providers are required to report certain adverse events related to COVID-19 vaccines to the Vaccine Adverse Event Reporting System. COVID-19 vaccination providers are also required to report vaccine administration errors, regardless of whether the error led to an adverse event.

When documenting vaccine administration in medical record systems, please note:

• For existing or established health center patients, health centers should follow their usual health documentation process and record the vaccination, as with all other services, in the patient’s health center medical record.
• For individuals who are not established patients of the health center and who are not accessing other health center services beyond the COVID-19 vaccination, the health center may either record the vaccination within the health center's medical record system or create and maintain a separate record.  At a minimum, the record created by the health center should identify the patient, the service provided, the location where the service was delivered, the name of the provider(s) delivering the service, and the date and time the service was delivered.
• For both established patients and individuals who are not established patients, the health center must record all CDC-required vaccine administration data elements (if not already recorded in the vaccine recipient’s record) and report this required data to the relevant system for the jurisdiction noted in their provider agreement. More information is available from CDC.

While health centers may determine whether vaccination records will be documented using their existing medical record system (e.g., the health center’s electronic health record (EHR)) or if they will maintain a separate set of immunization records (e.g., use a shared jurisdictional record system), whatever system is used, this record keeping system must enable the health center to submit the required COVID-19 vaccination data into the IIS within the specified timeframes and align with the health center’s state or jurisdictional accepted reporting option.

As a reminder, the Health Center COVID-19 Vaccine Program is designed as a separate, direct allocation for health centers, distinct from any vaccine allocation that health centers are receiving from their state or jurisdiction. Therefore, health centers must track and report total inventory for the Health Center COVID-19 Vaccine Program separately from their state or jurisdictional allocation.

(Added: 5/20/2021)

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 also seek reimbursement under the HRSA COVID-19 Coverage Assistance Fund (CAF) for the costs of administering COVID-19 vaccines to patients whose health insurance does not cover vaccine administration fees, or whose insurance does but typically has patient cost-sharing.

Consistent with section 330 requirements for in scope services, health centers that participate with the U.S. COVID-19 Vaccination Program 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.

(Updated: 5/19/2021)

Since no out-of-pocket costs are charged directly to individuals who receive a COVID-19 vaccination, health centers do not need to assess eligibility for the sliding fee discount program if the only service being delivered is the COVID-19 vaccination.

However, if individuals present for other in-scope health center services (for example, a routine primary care visit), health centers are required to continue assessing eligibility for and providing applicable sliding fee discounts and maximizing reimbursement, and they must continue to ensure that no patient is denied service based on inability to pay.

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. Participating providers are required 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. More information is available in the preceding question “What considerations apply to health centers’ billing for COVID-19 vaccination?” on this FAQ webpage.

(Added: 3/10/2021)

The Centers for Medicare and Medicaid Services (CMS) has information regarding provider reimbursement for the administration of COVID-19 vaccines. In addition, Federally Qualified Health Centers may request lump sum payments for administering COVID-19 vaccines in advance of cost report settlement. CMS will pay you for COVID-19 vaccines and administration at 100% reasonable cost, as is done for influenza and pneumonia vaccines. Contact your Medicare Administrative Contractor or view the April 1 edition of the CMS Medicare Learning Network Connects newsletter for more information.

(Updated: 4/19/2021)

The HRSA COVID-19 Coverage Assistance Fund (CAF) covers the costs of administering COVID-19 vaccines to patients whose health insurance does not cover vaccine administration fees, or whose insurance does but typically has patient cost-sharing.

The CAF reimburses eligible health care providers for claims associated with COVID-19 vaccine administration provided to underinsured individuals, who are defined for this purpose as having a health plan that either does not include COVID-19 vaccine administration as a covered benefit or covers COVID-19 vaccine administration but with cost sharing.

• There is no cost to patients for the administration of COVID-19 vaccines, and providers are expected to first submit a claim for vaccine administration to the individual’s health plan carrier for payment.
• Only claims that are denied or not fully paid by a patient’s health plan and/or other patient charges related to COVID-19 vaccine administration, including co-pays, deductibles, and coinsurance, are eligible for reimbursement.
• Claims will be subject to Medicare timely filing requirements.
• Providers are not required to ascertain a patient’s immigration status in order to receive reimbursement from the fund.

For additional information, view the CAF Frequently Asked Questions.

As a reminder, vaccine administration fees for uninsured individuals may be eligible for reimbursement through the HRSA COVID-19 Uninsured Program.

(Added: 5/19/2021)

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 on this FAQ webpage.

(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 preceding question “What liability protections apply to health center providers when an individual who receives a vaccine has an adverse reaction?” on this FAQ webpage.

(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.

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 HRSA Health Center COVID-19 Survey.

(Updated: 4/22/2021)

Health centers should pursue all reasonable opportunities to vaccinate every eligible person who wants to be vaccinated, understanding that this may increase the likelihood that vaccine will be wasted. To increase vaccination while still mitigating vaccine wastage, health centers may consider:

• Establishing and promoting standing vaccination days or half-days to increase the likelihood of large numbers of people presenting for vaccination on the same day.
• Vaccinating family members or friends who accompany patients to medical visits, even if they do not have an appointment that day.
• Contacting additional persons (e.g., from a waitlist) to use as many vaccine doses as possible.

Health centers should continue to prepare enough doses to meet daily scheduled or anticipated demand and administer vaccines in accordance with the manufacturer’s guidelines for multi-dose vials.

As a reminder, to be considered in scope, all vaccination activities must be provided on behalf of the health center through services and activities within their scope of project. 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.

In addition, to mitigate potential vaccine wastage, health centers may transfer vaccine doses received through the Health Center COVID-19 Vaccine Program from one health center to another health center, as long as both are part of the Health Center COVID-19 Vaccine Program. If no other health centers participating in the Health Center COVID-19 Vaccine Program are in need of vaccine, health centers may consider transferring vaccine to other eligible community partners. For more information see the question “Can a health center transfer vaccines allocated through the Health Center COVID-19 Vaccine Program to public health partners or other community organizations to support broader community vaccination efforts?” on this FAQ webpage.

For health centers that receive vaccine allocation from their state or jurisdiction, please refer to the state/jurisdiction guidelines regarding information on mitigating vaccine wastage.

(Updated: 6/11/2021)

You may provide COVID-19 vaccinations as part of routine primary care visits or with other in-scope services. However, in accordance with the CDC COVID-19 Vaccination Program Provider Agreement requirements, you may not:

• Require additional medical or other services during the visit as a condition for getting a COVID-19 vaccination;
• Charge patients for an office visit or other fee if COVID-19 vaccination is the only medical service given; or
• Balance bill for COVID-19 vaccinations.

As a reminder, if you provide other in-scope services (e.g., a routine primary care visit) in addition to the COVID-19 vaccination, you must assess eligibility for and provide applicable sliding fee discounts and also maximize reimbursement from third-party payor sources for the other primary care services provided. You must also ensure that you do not deny a patient any service based on their inability to pay. You can find specific information about billing for the administration of COVID-19 vaccinations in the question “What considerations apply to health centers’ billing for COVID-19 vaccination?" on this FAQ webpage.

(Added: 4/13/2021)

Your health center’s engagement in COVID-19 testing, treatment, and/or vaccine administration provides critical opportunities to connect people to essential health center services.

HRSA encourages you to engage with individuals who present for testing or vaccination to promote awareness of other health center services. This is an opportunity to support entry into care for those who lack a primary care medical home and/or to offer enrollment assistance with Medicaid, CHIP, and other affordable insurance options, including those available through the Marketplace special enrollment period.

(Added: 4/13/2021)

As a trusted community partner, your health center plays an important role in strengthening COVID-19 vaccine confidence among your patient population. As part of your routine delivery of primary care services, HRSA encourages you to offer patient-centered and culturally appropriate:

• Education about COVID-19 vaccines (see the CDC’s Vaccinate with Confidence resource);
• Information about how to make an appointment for a COVID-19 vaccine when ready; and
• Enabling services that reduce barriers to COVID-19 vaccine access, such as transportation or translation.

As a reminder, in accordance with the CDC COVID-19 Vaccination Program Provider Agreement requirements, you must administer the COVID-19 vaccine with no out-of-pocket cost to patients for the vaccine and may not require additional medical or other services during the visit as a condition for getting a COVID-19 vaccination.

(Added: 4/13/2021)

There is no federal legal requirement for parent or caregiver consent for COVID-19 vaccination, or any other vaccination. However, states and territories may have laws and regulations regarding consent for vaccination of minors. Health centers must administer COVID-19 vaccines according to applicable state and territorial vaccination laws and guidance, including those related to consent. Health centers should contact their state, tribal, and/or local health departments for further guidance. For more information and resources on adolescent vaccination, visit the CDC website.

(Added: 6/11/2021)

As private, nonprofit and public entity organizations, health centers may make business, personnel, and staffing decisions, and must do so in compliance with all Health Center Program requirements and all applicable federal, state, and local laws and regulations.

On September 9, 2021, the White House announced that CMS and the Occupational Safety and Health Administration (OSHA) will issue rules setting forth vaccine requirements applicable under certain conditions. We encourage health centers to monitor developments as these rules are issued. In addition to complying with Health Center Program requirements, health centers are responsible for complying with legal requirements for participation in Medicare and Medicaid as well as OSHA workplace requirements and other applicable federal, state, and local laws when developing employee policies regarding COVID-19 vaccination.

(Updated: 9/22/2021)