Reporting COVID-19 Vaccination Status in 2022

Reporting COVID-19 Vaccination Status in 2022

Three new diagnosis codes for reporting COVID-19 vaccination status will go into effect April 1, 2022. The codes were presented by the National Center for Health Statistics (NCHS) at the Sept. 14-15, ICD-10 Coordination and Maintenance Committee meeting, so they are not listed in the 2022 ICD-10-CM code book.

The new ICD-10-CM codes for reporting COVID-19 vaccination status are:

Z28.310    Unvaccinated for COVID-19

Z28.311    Partially vaccinated for COVID-19

Z28.39      Other underimmunization status

The ICD-10 Medicare Code Editor Version 39.1 will include these codes in its edits to validate correct coding on claims for discharges on or after April 1, 2022.

Added Feb. 2, 2022: The 2022 Official Guidelines for Coding and Reporting are updated at Section I.C.1.g.(1)n to include this guidance:

Code Z28.310, Unvaccinated for COVID-19, may be assigned when the patient has not received at least one dose of any COVID-19 vaccine. Code Z28.3111, Partially vaccinated for COVID-19, may be assigned when the patient has received at least one dose of a multi-dose COVID-19 vaccine regimen, but has not received the full set of doses necessary to meet the Centers for Disease Control and Prevention (CDC) definition of “fully vaccinated” in place at the time of the encounter.

Tabular Modifications

In the Tabular List of the 2022 ICD-10-CM code set, these new codes will be added under new subcategory Z28.31:

Z28 Immunization not carried out and underimmunization status

               Z28.3 Underimmunization status

(NEW)                  Z28.31 Underimmunization for COVID-19 status

The new Z codes are for tracking purposes only. For people who are not immunized or only partially immunized, “this is a significant modifiable risk factor for morbidity and mortality, and of interest for clinical reasons, as well as of value for public health,” the NCHS states in the Sept. 14-15, Committee meeting topic packet.

COVID-19 Stats

Between Jan. 1, 2020, and Nov. 13, 2021, the NCHS reports 765,332 COVID-19-related deaths in the United States. Texas has the highest rate of occurrence at 77,300 deaths and Vermont has the lowest occurrence rate at 351 deaths.

As of Nov. 18, the Centers for Disease Control and Prevention (CDC) reports that approximately 195.6 million people, or roughly 59 percent of the U.S. population, are fully vaccinated in the United States and 31.5 million have received a booster dose.

Vaccine Mandate

Under a new interim final rule with comment period (IFC), certain healthcare workers and staff must be inoculated with the first dose of COVID-19 vaccine by Dec. 6.

The Omnibus COVID-19 Health Care Staff Vaccination, published in the Nov. 5 Federal Register, requires Medicare and Medicaid-certified providers and suppliers to vaccinate all workers except those with legitimate exemptions. Applicable entities must also track and document workers’ vaccination statuses and exemptions. The mandate does not directly apply to healthcare entities that are not regulated by the Centers for Medicare & Medicaid Services (CMS) such as physician offices. However, CMS states in the IFC, “entities not covered by this rule may still be subject to their State or Federal COVID-19 vaccination requirements, such as those issued by Occupational Safety and Health Administration (OSHA) for certain employers.”

Effective Nov. 5, OSHA issued an emergency temporary standard (ETS) for protecting workers of large employers from COVID-19.

The ETA requires covered employers with more than 100 workers to develop, implement, and enforce a mandatory COVID-19 vaccination policy. Alternatively, employers can adopt a policy requiring employees to either get vaccinated or undergo weekly testing and wear a face mask at work. The OSHA ETS also requires employers to determine the vaccination status of each employee, obtain acceptable proof of vaccination status, and maintain records and a roster of each employee’s vaccination status.

UPDATE: CMS Vaccination Mandate Rule Blocked

HIPAA Concerns

The vaccine mandate creates a lot of questions for employers such as if they are responsible for the legitimacy of their employees’ vaccine status. “The price of fake COVID-19 vaccine cards and the number of vendors selling them have shot up since President Joe Biden announced his vaccine mandate plan,” reports Jenni Bergal (PEW, Sept. 16, 2021). The new ICD-10-CM codes may be a way of legitimizing vaccination claims, but this brings up other concerns.

For example, is asking employees of their vaccination status a violation of the HIPAA Privacy Rule? “No,” states the Department for Health and Human Services (HHS) in a guidance material. “The Privacy Rule does not apply to employment records, including employment records held by covered entities or business associates in their capacity as employers.”

In fact, a covered entity or business associate may require their employees to sign a HIPAA authorization permitting a healthcare provider to disclose their employees’ COVID-19 or varicella vaccination records, according to HHS.

Covered entities and business associates are, however, responsible for protecting the privacy of that health information.

Renee Dustman
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Renee Dustman, BS, AAPC MACRA Proficient, is managing editor - content & editorial at AAPC. She holds a Bachelor of Science degree in Media Communications - Journalism. Renee has more than 30 years' experience in journalistic reporting, print production, graphic design, and content management. Follow her on Twitter @dustman_aapc.

17 Responses to “Reporting COVID-19 Vaccination Status in 2022”

  1. Wynonna Nash says:

    There are codes for under or not vaccinated but not for fully vaccinated. If a patient comes in testing positive for Covid-19 there is a code for that, but no code to reflect the patient was fully vaccinated for months . Would it not be more efficient if there was a code to reflect this accurately? If there is not a code to reflect this, how are all of the numbers the CDC are reporting are accurate when the information they are given are not accurate? Thank you .

  2. Lisa Foreman says:

    It sounds like they are assuming if they are not vaccinated and they are not partially vaccinated, then they must be vaccinated. However, no statistics will be 100%. Codes are only coded if documentation is there.

  3. Jacob Villa says:

    I may lose my certifications over this. I refuse to code vaccination statuses, over such an equivocal and controversial mandate. There is no status code for HBV/HCV statuses, hell, not even a flu vax status. This stinks to high hell, and I’m not alone in the HIM community in that assessment.

  4. Leann S says:

    I completely agree!! Just like testing only the unvaccinated. Incomplete reporting for statistics to be manipulated.

  5. Mary P says:

    A very biased reporting of COVID related deaths between two very differently populated states. For the record Texas has 29 million more people in its population than Vermont. So of course Texas has more deaths. Keep your political views and opinions OUT of your professional coding articles. AAPC is for coding knowledge and education, not the political band stand. Definitely sacrificed your integrity.

  6. Renee Dustman says:

    No political agenda intended. Just reporting the data.

  7. Chantelle says:

    I disagree with the HIPAA violation part. How is knowing some one else’s vaccine status (medical information) not a HIPAA violation? That would be like me asking random people if they have HIV/Aids, herpes and so forth.

  8. LAURIE says:


  9. Renee Dustman says:

    I have not seen a law saying as much.

  10. FH says:

    This is a total violation of a patients privacy. Not to mention inaccurate date collection. We do not record an unvaxed person for Flu, Pna, Hep B or Shingles. I am concerned this will be used against a person in the future by our Government. Also the CDC cannot regulate what a person injects into their body.

  11. Michelle says:

    Z28.3 (previously V15.83) has always been available to show underimmunization status. See Coding Clinic 4Q 2009 pages 115-118. They now have created ones specific to COVID vaccine.

  12. Renee Dustman says:

    Note: Z28.3 is deleted as of 4/1/22

  13. Cora says:

    How will the COVID reinfection(s) of fully vaccinated cases be reported/counted if there is no code for fully vaccinated status?

  14. Renee Dustman says:

    According to AFP (, there isn’t a code yet for fully vaccinated because “fully vaccinated” hasn’t been established yet. So, you are right, this is a conundrum!

  15. LISA COHEN says:

    there is a typo- Code Z18.310 (THIS SHOULD BE Z28.310)

  16. Renee Dustman says:

    thank you

  17. RB says:

    Who else is saddened by the last 2 years? As a medical coder and we have witnessed a lot these last 2 years. My question is, do we know if anyone has looked into the reporting of Covid-19 per the CMS (centers for Medicare and Medicaid services) guidelines? Coders are required to follow guidelines per CMS. My background is Urgent Care Coding and Emergency Department Coding, I have fine tooth combed previous and recent guidelines that have come out by CMS and have come to a conclusion that if a health facility receives payment from Medicare or Medicaid they are under a blanket waiver (CMS 1135 Waiver). Now, if you allow me to elaborate a little, this is significant to the fraud and abuse of medical facilities and physicians during the pandemic. Government funded payments, are paid out much quicker than private insurance and also guarantee payment. Physicians and Presidents of our large facilities know this. Per current guidelines, any Covid-19 test given during a visit require Modifier DR (disaster related) and CS (cost sharing), this is not just exclusive to government forms of payment, all charts when a test is administered are required to add these and in return the Government will pay the claim. Z208.22- which means exposure to Covid-19 and since Covid-19 is in the ‘community’ all claims with a test no matter the result get this code and the government pays out. We have all seen the stories of patients coming in for symptoms totally unrelated to any Covid-19 related and when documents are reviewed Covid-19 is listed as the primary diagnosis. Per CMS guidelines any positive test result, if it meets the requirements for primary listed diagnosis should be reported first. Also physicians have full discretion with Covid-19, they do not need a positive test result to diagnosis Covid-19, if they think they have, they list it. Big green dollar signs in they eyes of all our medical professionals who have not stood against the Covid-19 Plandemic, they lined the pockets for themselves as well as the Elites, who run the organizations from which our guidelines to document medical claims comes from. The whole process for classifying disease is ruined and per CMS guidelines these vaccination status codes are for ‘tracking purposes’ only. Anyone else having a hard time following these guidelines morally and ethically?