In response to Congressional action to provide states with additional funding to support the ongoing COVID-19 pandemic response, MTAC expresses support for federal agency actions that will specifically address the nationwide vaccination campaign.

Vaccine uptake by Medicaid beneficiaries and other vulnerable communities is particularly critical. Several Medicaid-covered populations have been disproportionately affected by the COVID-19 pandemic. While COVID-19 vaccination rates among adults receiving at least one dose of the vaccine is reaching 60% in several states (with a nationwide goal of 70% by July 4), the uptake rates are varied by subpopulations, and there are signs already that the pace of vaccinations is declining considerably. This is why it is imperative for policymakers to address additional supports that high-needs populations require so they are not left behind.

Thankfully, non-emergency medical transportation through Medicaid, recently codified by Congress as a required Medicaid benefit, is a valuable tool that can be leveraged in Medicaid and beyond to connect high-needs populations to life-saving care, including the COVID-19 vaccine.

MTAC thanks the Centers for Medicaid & Medicare Services (CMS) for recognizing the value of transportation to and from COVID-19 vaccines for beneficiaries who are receiving home- and community-based services. In its May 13 guidance to states, CMS informed states that they may use enhanced temporary federal matching funds provided by the American Rescue Plan Act to provide transportation to vaccine sites for individuals receiving HCBS services.

CMS can still do more to encourage vaccine uptake by Medicaid beneficiaries. Congress provided that states would be reimbursed for 100% of their costs for COVID-19 vaccines and their administration, allowing states to reduce potential barriers like cost-sharing or prior authorization controls. However, additional CMS guidance to states is still needed to specify what services count as vaccine administration expenses. As MTAC raised to the Biden administration in March, including NEMT services in the definition of administration of the vaccine would help facilitate access to the vaccine and reduce potential transportation barriers.

Even without policy clarification from CMS, MTAC’s transportation management company members and other allied members are stepping up by providing eligible Medicaid beneficiaries access to transportation to vaccine sites throughout the nation. As the Biden administration takes a whole-of-government approach to ending the COVID-19 pandemic, MTAC will continue to highlight NEMT as an important piece of the nation’s health care and transportation infrastructure.