As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the fiscal year 2016 CMS Physician Fee Schedule and Other Revisions to Part B Proposed Rule.
AVAC consists of more than 35 organizational leaders in health and public health that are committed to tackling the range of barriers to adult immunization and to raising awareness of the importance of adult immunization.
AVAC works towards common legislative and regulatory solutions that will strengthen and enhance access to adult immunization across the health care system. Our mission is informed by a growing body of scientific and empirical evidence in support of the benefits immunizations provide by improving health, protecting lives against a variety of debilitating and potentially deadly conditions and saving costs to the healthcare system and to society as a whole.
AVAC priorities and objectives are driven by a consensus process with the goal of enabling the range of stakeholders to have a voice in the effort to improve access and utilization of adult immunizations. One of our key coalition priorities is to advocate for federal benchmarks and measures to encourage health plans to track, report and achieve increased adult immunization rates among subscribers. Our comments focus on the following topics: 1) retaining current immunization quality measures; 2) developing an updated pneumococcal measure to reflect current ACIP recommendations; 3) including additional immunization quality measures in the PQRS; and 4) increasing reimbursement for vaccine administration.
We commend CMS for maintaining a number of immunization measures in the Physician Quality Reporting System (PQRS) as these measures are critical preventive services benchmarks. Monitoring immunization status and reporting of offered and administered immunizations to patients helps to ensure that the range of available immunizations remain a priority and in the forefront of clinical care standards. Reducing the number of missed immunization opportunities, particularly among Medicare beneficiaries, is critical to improving health and reducing the burden of vaccine preventable disease.
In particular, we appreciate the retention of the Annual Influenza Vaccination (ACO #14) and the Pneumonia Vaccination Status for Older Adults measure (ACO #15) in the Medicare Shared Savings Program (MSSP’s) Preventive Health domain. These two measures are an important baseline for access to influenza and pneumococcal vaccination services and will help ensure protection against vaccine preventable conditions that exact a heavy toll on adults in terms of health and productivity costs.
The disproportionate burden of disease and the potential benefits of vaccination among adults make continued monitoring of immunization access and utilization a key priority. According to the Centers for Disease Control and Prevention (CDC), an estimated 900,000 Americans get pneumococcal pneumonia each year, resulting in as many as 400,000 hospitalizations and more than 53,000 deaths. Despite the fact that most pneumococcal pneumonia deaths each year are adults, 67 million adults at increased risk remain unvaccinated. By contrast, a recent CDC study of flu-associated deaths prevented over a nine year period from 2005-2006 through 2013-2014 found that nearly 89 percent were in people 65 years of age and older.
In the immediate term, we encourage CMS to work with relevant stakeholders and quality measure organizations to develop an updated pneumococcal immunization measure that reflects the current Advisory Committee for Immunization Practice (ACIP) recommendation for PCV13 and PPSV23 vaccination in adults age 65 and older as well as at risk adults 19-64 years old. The Health and Well-Being Committee for the National Quality Forum (NQF) recently proposed standards specifications for pneumococcal measures in order to better align measures across healthcare settings and to bring measures in accordance with ACIP recommendations.1 AVAC encourages CMS to work with NQF since these this work reflects CMS’ broader goals around quality measure alignment.
Such a measure could be incorporated in the measure sets for the multiple chronic conditions group as well as the diabetes measures group. Individuals with diabetes and multiple chronic conditions are at significantly higher risk of complications and death from pneumonia. According to the American Diabetes Association, people with diabetes are three times more likely to die with flu and pneumonia, yet only a third of people with diabetes receive a pneumococcal vaccination.
Similarly, AVAC recommends CMS also consider expanding the Influenza Immunization screening measure (NQF #0041) that is currently used in the multiple chronic conditions and diabetes measures groups and explore adding the Pneumonia Vaccination Status for Older Adults (NQF#0043) to the cardiovascular prevention measures group in the final rule. These two measures represent an important baseline for access to influenza and pneumococcal vaccination services and are being utilized effectively in other settings under the Medicare program. We believe they will greatly reduce the number of missed immunization opportunities for heart disease patients improve health and reduce the burden of vaccine preventable disease.