by Michael Nevradakis, Ph.D.
Medicare will reimburse doctors for the cost of diagnosing and treating suspected vaccine-related adverse effects, according to a new Centers for Medicare & Medicaid Services (CMS) policy announced last week and published today in the Federal Register.
Under the rule, CMS will introduce billing code G0576 to reimburse physicians and other eligible Medicare providers for every 15 minutes of qualifying work evaluating, diagnosing, treating or counseling patients with suspected vaccine-related adverse reactions.
The reimbursement payment will be in addition to what Medicare already pays for a standard office visit.
Doctors can qualify for reimbursement by documenting when the suspected adverse reaction occurred in relation to vaccination, evaluating other possible causes of the patient’s symptoms and maintaining supporting medical records.
A CMS spokesperson told The Defender that reimbursement would not depend on a final determination that a vaccine caused the reported symptoms.
“Physicians will not be paid based on whether a report is ultimately determined to be related to a vaccine, nor would reimbursement change the standard for evaluating those reports,” the spokesperson said.
CMS framed the new code as a way to support the Trump administration’s Make America Healthy Again (MAHA) initiative.
“Medicare should reward clinicians for keeping people healthy,” U.S. Health Secretary Robert F. Kennedy Jr. said in a statement.
Last month, the U.S. Department of Health and Human Services (HHS) referenced the initiative when it launched a federal Vaccine Injury Center. At the time, HHS officials said doctors would be reimbursed for time spent reporting suspected vaccine injuries to the Vaccine Adverse Event Reporting System (VAERS).
However, the final rule does not explicitly authorize or exclude reimbursement for submitting VAERS reports, leaving it unclear whether physicians can bill for time spent completing and submitting the reports.
CMS did not answer a follow-up request by press time seeking clarification on whether G0576 covers the time spent completing and submitting VAERS reports.
The code, which will also apply to telehealth visits, takes effect Jan. 1, 2027.
‘A pro-science move’
In a Facebook post last week, MAHA Action, a nonprofit advocacy group supporting the MAHA agenda, said the new policy is part of “HHS’s broader push to strengthen vaccine injury research, reporting, and patient care.”
Tony Lyons, president of MAHA Action, told The Defender the new policy changes the incentive structure for American physicians “for the first time in a generation” and is part of “a seismic shift in the way our government learns about, responds to, treats and compensates for vaccine injuries.”
Groups representing the vaccine-injured also welcomed the policy. Brianne Dressen, co-founder of React19, an advocacy group for vaccine-injured people and their families, said the new policy follows years of advocacy.
“We actually met with CMS back in 2025 and asked them to do this,” Dressen said. “I am glad to see they have been able to get this across the finish line.”
Dressen said her group “fully supports” the new policy, calling it “a pro-science move” that may help physicians treat serious vaccine injuries that are “some of the most complicated conditions for them to treat.”
“More complicated means more time required one on one with the patient, more time researching the injury and overlapping comorbidities, and time collaborating with other providers. All of that time costs money,” Dressen said.
However, some medical organizations questioned the new policy. In a September letter to CMS Administrator Mehmet Oz, the American Academy of Family Physicians said the code “overlaps with existing codes” and that CMS should more clearly distinguish the services it covers from those already reimbursable.
The group added that it “does not expect the code will be frequently used,” because vaccine reactions “are not typical” and are usually mild.
But Dr. Michelle Perro, a pediatrician, welcomed the new code — and the federal government’s “recognition that evaluating a vaccine injury requires time, clinical investigation and follow-up.”
Will Medicaid and private insurers cover the new code?
The new code will be valid for Medicare patients, most of whom are 65 or older. However, it doesn’t automatically require state Medicaid programs or commercial insurers to provide the same reimbursement.
Medicaid is jointly funded by the federal government and individual states, which administer their own programs. While many state Medicaid programs choose to adopt CMS codes and mirror the Medicare fee schedule, they are not federally mandated to do so.
Medicare Advantage plans, administered by private insurers under federal contracts, must generally cover the same medically necessary services as traditional Medicare.
However, insurers can negotiate different reimbursement rates with participating physicians, meaning the new CMS billing code does not necessarily guarantee them additional payment under Medicare Advantage.
While private commercial insurance plans use standardized medical billing codes, they are not obligated to reimburse every code recognized by Medicare.
The CMS spokesperson told The Defender that the new code will be “available for other payers to use.”
The Defender contacted 24 major private insurers and insurance plans to ask whether they intend to reimburse providers under G0576 beginning in 2027. A spokesperson for CVS Health responded, “We are reviewing the new code and continue to comply with CMS program requirements.”
Unclear if CMS will reimburse time spent filing VAERS reports
Although HHS initially highlighted reimbursement for VAERS reporting, the final CMS rule focuses on clinical evaluation and management of suspected vaccine injuries. It remains unclear whether time spent filing reports qualifies for payment under G0576.
One reason for this may be that doctors are already legally obligated to file such reports for suspected vaccine injuries in certain situations.
For instance, under the National Childhood Vaccine Injury Act of 1986, healthcare providers are required to report specified adverse events occurring within designated time periods after vaccination, and reactions or injuries identified by manufacturers as contraindications to further doses.
The Centers for Disease Control and Prevention encourages reporting “clinically significant” adverse events following vaccination, even when it is uncertain if the vaccine caused them.
In practice, vaccine injuries have traditionally been underreported and undercounted. A 2011 Harvard Pilgrim study found that fewer than 1% of vaccine-related adverse events are reported to VAERS.
Physicians ‘need training’ on how to identify, treat vaccine injuries
Some physicians and advocates for the vaccine-injured said doctors have long been reluctant to evaluate patients for potential vaccine-related adverse events or to consider a possible link between vaccination and those injuries, and that they receive limited training to recognize or treat such injuries.
“Most Medicare-accepting clinicians do not know how to identify and treat vaccine injuries,” said pediatrician Dr. Elizabeth Mumper. “They need training on how to recognize those injuries.” Until such training occurs, the CMS code likely “won’t be adequate to heal the vaccine-injured.”
According to Perro, while physicians “have long been able to bill for evaluating and treating adverse reactions to medications,” there are currently no billable medical codes for vaccine-related adverse events.
Advocates said the new CMS policy may help encourage doctors to perform such evaluations and treatments.
“Patients reporting vaccine adverse effects have long said they struggle to find doctors willing or able to devote enough time to their cases. Now Medicare is creating a specific pathway to support that care,” MAHA Action wrote.
Perro said the success of the new code will depend on whether “physicians know about the code, whether payment adequately supports the work and whether patients can find clinicians prepared to investigate their symptoms.”
Could new code create inappropriate financial incentives for doctors?
The new policy also raises questions about whether additional reimbursement could encourage physicians to attribute symptoms to vaccination, similarly to how physicians are financially incentivized to administer recommended childhood vaccinations — a practice often criticized by medical freedom advocates.
Perro said such incentives “deserve scrutiny,” and that the payments “should support meticulous clinical work without rewarding a predetermined conclusion.”
“A physician should be paid for taking a history, examining the patient, considering alternative explanations, documenting findings and developing a treatment plan. That work has value, whether the eventual conclusion supports an adverse reaction to a vaccine or not,” Perro said.
Dressen questioned the notion that physicians would “profit” from diagnosing vaccine injuries under the new policy. She said evaluating suspected vaccine injuries is often a complex and expensive process, prompting some physicians to switch to cash-pay practices rather than rely on insurance reimbursement.
“No doctors we work with at React19 are ‘profiting’ off of treating injured patients. They typically have to offset the loss of seeing these complex patients with other patients,” Dressen said.
Lyons said the new plan will incentivize physicians to treat patients rather than to prescribe potentially unnecessary medications or treatments.
“Doctors, if this works out as planned, will be able to make more money by doing things that improve the health outcomes of their patients than they previously made by overmedicalizing them. This is a truly epic development in the history of medicine,” Lyons said.
The CMS spokesperson said the new plan will also contribute to improved vaccine safety monitoring — a key MAHA tenet. Last year, Kennedy promised better vaccine injury tracking as part of the administration’s MAHA agenda.
“Rigorous surveillance, follow-up investigation, and transparency about what the evidence shows are essential to giving Americans accurate information and rebuilding public trust,” the spokesperson stated.
Perro said the policy could also “make patients more willing to bring forward their concerns about vaccine injuries.” Greater recognition and documentation of suspected reactions, she said, “could also improve safety monitoring.”
Via https://tdefender.substack.com/p/medicare-reimburse-doctors-vaccine-injury-diagnosis-treatment
