Recent Department of Health and Human Services Meeting Uncovered Plans to Establish an Expansive Federal Database Designed to Monitor Individuals Who Refused the Covid-19 Vaccination


On September 14, 2021 the Center for Medicare and Medicaid Services (CMS) convened a panel of public health professionals to formulate strategies for federal authorities to monitor those who refuse vaccinations.




“There has been considerable interest in coding people who are not immunized against Covid 19,” exclaimed David Berglund, Medical Officer. “Allow me to demonstrate it.”

During this period of the Covid 19 pandemic, immunization has become a reality for many people; providing them with protection from the virus. With that in mind, there is an expressed interest to identify individuals who have not been vaccinated or only partially vaccinated against the disease.

He further noted that there is currently a considerable modifiable risk factor for mortality and morbidity, which presents both clinical appeal and public health value. Therefore, it would be beneficial to track these factors accordingly.

Berglund subsequently unveiled the timeline for implementation of the ICD-10 [International Classification of Diseases, 10th edition] codes.

To accurately track and monitor the progress of Covid-19 vaccinations, NCHS is introducing codes to be implemented on April 1st, 2022. We invite you to provide your comments regarding this proposed update by October 15th, 2021 – just one month away. This would help us see how we could best incorporate these new codes into our current classification system.

The National File was the first to uncover the upcoming September 2021 CMS meeting.

In April of 2022, the Department of Health and Human Services’ CMS division brought out Covid vaccination codes to be included in the ICD-10.

  • Z28.310 Unvaccinated for Covid-19
  • Z28.311 Partially vaccinated for Covid-19
  • Z28.39 Other under-immunization status

According to the ICD-10-CM table, these codes are not for those who have been determined by a healthcare provider as ineligible for receiving the Covid-19 vaccine. The primary use of ICD-10 codes is in regards to healthcare records, insurance billing and health data analysis.


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