Use These New Immunization Counseling Codes in Your Practice
When vaccine visits result in refusal, these codes will still result in reimbursement. Beginning January 1, three new CPT® codes took effect, introducing a long-awaited solution for reporting physician or qualified health professional (QHP) immunization-related counseling and clinical services when no vaccine is administered. These time-based, standalone codes acknowledge a reality long familiar to pediatric clinicians: some of the most time-intensive and clinically meaningful immunization encounters occur precisely when families are hesitant, resistant, or unwilling to proceed with vaccination. The new immunization counseling codes are as follows: The introduction of these codes represents an important step toward recognizing the cognitive, emotional, and clinical labor involved in addressing vaccine hesitancy and misinformation. At the same time, their success — or failure — will depend heavily on payer interpretation, operational readiness, documentation expectations, and how costs are ultimately experienced by families. Recognizing the Work That Has Always Been There Vaccine counseling is rarely a brief or transactional interaction. Pediatricians routinely spend significant time discussing safety concerns, correcting misinformation, and navigating deeply held beliefs — often within already packed preventive visits. When these conversations end in vaccine refusal or deferral, the work itself has historically gone uncompensated and largely ignored in claims data. CPT® codes 90482-90484 are designed to capture this work. They are time-based counseling codes, not vaccine administration codes, and may be reported even when immunizations are ultimately declined. In doing so, they validate the clinical importance of sustained engagement with hesitant families rather than incentivizing rushed or avoidant interactions. Under-Immunization Is Now a Reportable Clinical Condition Beyond reimbursement, these new codes offer an opportunity to better define and track under-immunization as a clinical and public health issue. When paired with existing ICD-10-CM diagnosis codes — such as Z71.85 (Encounter for immunization safety counseling) and Z28.xx (Immunization not carried out and underimmunization status) — pediatric practices can more accurately document the prevalence and nature of vaccine hesitancy. This alignment supports improved data capture, population health analysis, and policy discussions grounded in real clinical encounters. For years, pediatricians have managed under-immunization without adequate tools to reflect that work in administrative data or quality reporting. These codes help close that gap. Payer Readiness and Coverage Remain Unknown Despite their promise, significant uncertainty about using the new codes remains. It is not yet clear whether payers will be uniformly prepared to accept and adjudicate claims for codes 90482-90484 on the effective date. Early implementation may be complicated by system limitations, delayed fee schedule placement, or inconsistent coverage determinations across commercial, Medicaid, and managed Medicaid plans. Equally unclear is whether these services will be classified as preventive and covered at 100 percent, or whether patient cost-sharing will apply. For families enrolled in high-deductible health plans, even modest charges could come as an unwelcome surprise. Inconsistent payer policies may further complicate billing and patient communication. Be Ready for Potential Pushback Perhaps the most challenging aspect of implementing these codes will not be billing mechanics, but patient experience. Families who decline vaccines may not perceive counseling as a service they requested — and may react with frustration or anger if they later receive a bill for that discussion. In an environment where trust in healthcare is already fragile, unexpected financial responsibility risks undermining relationships that pediatricians work hard to preserve. Practices may find themselves navigating a difficult tension between ethical care, transparency, and financial sustainability. Clear communication, thoughtful workflows, and advanced consideration of patient responsibility will be essential to minimizing conflict and maintaining trust. Documentation Is Key As with any new codes, careful documentation will be essential. Records should clearly support the time spent, the content and complexity of counseling, and the clinical context of the encounter. However, there is legitimate concern that documentation standards could become overly rigid or inconsistently applied, leading to denials or post-payment audits that discourage appropriate use. These codes should support, not penalize, clinicians who engage thoughtfully and in good faith with families facing complex immunization decisions. New Codes Call for Thoughtful Implementation CPT® codes 90482-90484 offer an opportunity to better align reimbursement, data collection, and clinical reality in pediatric care. To realize that potential, payers, policymakers, and practices must approach implementation with care. That means clear guidance, operational readiness, reasonable documentation expectations, and sensitivity to the financial impact on families must all be taken into account. Pediatricians have always done the hard work of vaccine counseling. These codes finally acknowledge it. Even post-implementation, practices should proactively engage contracted payers to confirm coverage, clarify documentation requirements, and ensure claims are processed accurately. Doing so can help minimize patient confusion, reduce the risk of denials, and support both clinicians and families as these codes become part of routine practice. Donna Walaszek, CCS-P, Billing Manager, Northampton Area Pediatrics,
Northampton Massachusetts
