AVAC Offers Comments on the Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2022

AVAC managers sent a letter to the Centers for Medicare & Medicaid Services offering comments on the Medicare Program: Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2022. 

Centers for Medicare & Medicaid Services 
Department of Health and Human Services 
Attention: CMS-1746-P 
P.O. Box 8016 
Baltimore, MD 21244-8016 

To Whom It May Concern: 

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2022. 

Specifically, AVAC wishes to highlight its strong support for the following proposals included in this proposed rulemaking: 

  • Efforts to close the Health Equity Gap and the opportunity to offer our views on important actions that are necessary to address longstanding disparities in adult immunization rates among minority and underserved populations. 
  • Adoption of a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure. 
  • Advancing Health Information Exchange through the development of quality measures and implementation of interoperability standards that will facilitate and improve immunization record reporting and real-time information sharing across health care providers, facilities and public health. 
  • Inclusion of the Adult Immunization Status (AIS) measure in an expanded SNF VBP Program. 

AVAC consists of over 60 organizational leaders in health and public health that are committed to driving federal policy changes that will strengthen and enhance access to adult vaccines and awareness of the importance of adult immunization. AVAC works towards common legislative and regulatory solutions through 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. 

Closing the Health Equity Gap – RFI 

AVAC appreciates the opportunity to respond to the request for information on closing the health equity gap included in the proposed rule. Even before the COVID-19 pandemic, vaccine preventable illness devastated the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine-preventable diseases while adult coverage has lagged behind Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography. 

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have eroded further, leaving communities vulnerable to preventable disease, illness, and outbreaks. An analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.4 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates).5 Long-standing health disparities are also laid bare in these trends. Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 vaccine compared to 53% of white Americans. Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population. These trends could have serious consequences for the future, threatening widespread outbreaks of vaccine preventable conditions. We are grateful for CMS’ commitment to addressing systemic inequities that have resulted in poor health outcomes for certain populations. We commend CMS for finalizing in the FY2020 SNF PPS final rule the adoption of standardized patient assessment data elements (SPADEs) that include several social determinants of health (SDOH) and appreciate the opportunity to offer recommendations for expanded measurement and data collection that will help address gaps in health equity with respect to immunizations. 

First, AVAC urges to CMS to promote dissemination and adoption of the National Vaccine Advisory Committee (NVAC) Standards for Adult Immunization Practice1. This standard of practice for immunizations would ensure that Medicare beneficiaries have equitable access to information about recommended vaccines and the opportunity to receive those vaccines from a trusted health care provider. Assessment of immunization status through adoption of NVAC adult standards of care and implementation of adult 

Immunization status measure is a vital component to addressing longstanding disparities in access to immunization and will ensure that all Medicare beneficiaries receive a strong immunization recommendation from their provider and have the resources they need to make an informed decision. Widespread implementation of the NVAC Standards for Adult Immunization Practice is also an important first step toward advancing the Healthy People 2030 developmental measure to increase the proportion of adults age 19 or older who get recommended vaccines (IID-D03).

Another important element to closing the equity gap is consistent data collection and real-time reporting. The COVID-19 pandemic has illustrated the need for investments in our nationwide immunization data framework, as well as the dissemination and adoption of federal guidelines and incentives to encourage consistent reporting and widespread utilization of immunization information systems (IIS) across provider settings. In order to effectively identify and address health equity gaps, there must be strong and clear criteria in place for data reporting elements, provider usage, along with baseline standards interoperability, bidirectional exchange, data quality and security. AVAC encourages CMS to work with the HHS Office of Disease Prevention and Health Promotion to include the Healthy People 2030 lifespan IIS reporting3 developmental measure in its strategy to close equity gaps for adult immunization. Robust immunization record data reporting will empower providers, patients and caregivers to make educated decisions about vaccinations, reduce missed opportunities for immunization and minimize the likelihood of overvaccination, and help inform health care system efforts to close health equity gaps and prevent disease outbreaks. 

Lastly, AVAC also expresses support for the use of Quality Improvement Networks and Quality Improvement Organizations (QIN-QIOs) as a means to address the core priority areas outlined in the CMS Equity Plan for Improving Quality in Medicare. The three priority areas which inform CMS policies and programs are: (1) Increasing understanding and awareness of health disparities; (2) developing and disseminating solutions to achieve health equity; and (3) implementing sustainable actions to achieve health equity. The QIN-QIOs have a demonstrated track record of success in testing and evaluating innovative and effective strategies for improving immunization coverage rates among 

targeted Medicare populations. AVAC encourages CMS to continue to utilize the QIN-QIOs for this purpose and urges CMS to include in the list of tasks outlined in future scopes of work (SOW) strategies to improve immunization coverage rates among hard to reach rural and geographically underserved areas as well as among disabled, homebound, inpatient and congregate care patient populations. 

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure 

AVAC also appreciates the opportunity to express its strong support for CMS’ proposal to add a new COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to the FY 2023 SNF QRP. The COVID-19 pandemic had a disproportionate and devastating impact on older adults living in long-term care and congregate care settings. This new measure would require SNFs to report on COVID-19 HCP vaccination in order to assess whether SNFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of SNFs to continue serving their communities throughout the COVID-19 PHE and beyond. Under this proposal, SNFs would report the vaccination data through the Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) beginning October 1, 2021. 

AVAC believes this measure is vitally important to protect the health and wellbeing of older adults in SNFs and reporting of this measure through the NHSN helps to ensure transparency and accountability in community infection prevention and control efforts and is consistent with other HCP vaccination measures intended to preserve health and mitigate infectious disease outbreaks in long-term care settings. We know from reporting of influenza vaccination coverage of HCPs that provider uptake of the vaccine is also associated with that provider recommending vaccination to patients and encourages greater patient vaccination uptake. HCP vaccination can also potentially reduce illness-related missed work and disruptions to patient care. Lastly, reporting of HCP vaccination rates helps inform patients and caregiver choice when considering facilities from which to seek care, particularly for those at high-risk for developing serious complications from COVID–19. While data on the effectiveness of COVID–19 vaccines to prevent asymptomatic infection or transmission is limited, AVAC believes the COVID-19 HCP vaccination measure should nonetheless be included as part of efforts to assess and reduce the risk of transmission of COVID–19 within SNFs and urges CMS to maintain this proposal in the final rule. 

Fast Healthcare Interoperability Resources (FHIR) in support of Digital Quality Measurement in Quality Reporting Programs – RFI 

AVAC appreciates the work of the Department of Health and Human Services to “encourage and support the adoption of interoperable health information technology and to promote nationwide health information exchange to improve health care and patient access to their health information.” Promoting the use of consistent patient data sets across health care settings can be vitally important to ensure quality patient care and health outcomes while reducing the reporting burden on providers. Additionally, timely and accurate reporting of immunization record data is also of great importance for public health disease surveillance and outbreak prevention activities. Consistent data collection and reporting is a foundational element for successful quality measurement, transparency, and accountability. 

AVAC fully supports greater use of electronic clinical quality measures (ecQMs) across health care programs managed by HHS, including the Centers for Medicare and Medicaid Services (CMS), the Health Resources and Services Administration (HRSA), among other agencies. As CMS seeks feedback on definitions for digital quality measures (dQMs) for the SNF Quality Reporting Program (QRP), we would encourage CMS to look to existing ecQM resources that are available through the National Coordinator for Health Information Technology6 and as well as uniform data system modernization efforts within the Bureau of Primary Health Care at HRSA. Greater consistency in the adoption and use of electronic quality measures and a common reporting standard across HHS programs that serve vulnerable populations of all ages and across health care settings will improve overall quality of patient care, drive better health outcomes, as well as inform and empower patients, without creating an additional complexities and reporting burdens on health care providers. 

In terms of vaccine data for patients in SNF and long-term care settings, AVAC supports incentivizing interoperable and bidirectional immunization data reporting to immunization information systems, leveraging tools and measures through the SNF QRP. As previously stated, provider, patient and caregiver access to immunization record data is essential to addressing health inequities in immunization coverage for the COVID-19, as well as the range of routinely recommended vaccines important to protecting the health and wellbeing of Medicare beneficiaries in long-term care and SNF settings. 

Expanded SNF VBP Program 

AVAC is grateful for the opportunity to present its views in response to the proposed rule request for input from stakeholders on quality measures should be considered under an expanded SNF VBP. As the proposed rule notes, the Consolidated Appropriations Act, 2021 allowed the Secretary to expand the SNF VBP program and apply up to ten measures with respect to payments beginning in FY 2024, which may include measures of functional status, patient safety, care coordination, or patient experience. 

Quality measurement programs through Medicare play a critical role in promoting improved quality and encouraging adherence to and consistent utilization of recommended health care interventions, including adult vaccines. Vaccines play a vital role in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. The Department of Health and Human Services (HHS) recognizes that immunization is an important tool to keep people healthy and reduce avoidable health care costs across the lifecourse, especially given the COVID-19 pandemic and annual flu seasons. As CMS notes, the expanded SNF VBP measure set assess the quality of care that long-term care facilities provide, regardless of payer, but certainly the vast majority of patients are beneficiaries. 

Adult Immunization Status Measure 

As CMS considers a range of measures aimed at the quality of patient care with the goal of improving the overall patient experience and health outcomes, AVAC urges CMS to include of an Adult Immunization Status (AIS) measure in an expanded SNF VBP. The AIS measure is a composite of several age-recommended vaccines for adults, comprising influenza, pneumococcal, zoster, and Tdap vaccines. Adoption of the composite measure will provide a sound, reliable and comprehensive means to assesses the receipt of routinely recommended adult immunizations vital to healthy aging and prevention of avoidable illness. The AIS would reduce the reporting burden on providers while also incentivizing them to follow the National Vaccine Advisory Committee (NVAC) Practice Standards for Adult Immunization Practice1 to assess, recommend, administer or refer and document the vaccines the patient may (or may not) have received. 

Several years ago, AVAC released a White Paper outlining the value and imperative of quality measures for adult vaccines.2 The report highlights the role of vaccine quality measures in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. Quality measurement programs through 

Medicare play a critical role in promoting improved quality and encouraging adherence to and consistent utilization of recommended adult vaccines. 

The addition of an AIS quality measure to the SNF VBP would meet the three core strategies underlying the movement toward a truly patient-centered health care delivery system by: 1) Improving the way clinicians are paid to incentivize quality and value of care over simply quantity of services; 2) improving the way care is delivered by providing clinical practice support, data and feedback reports to guide improvement and better decision-making and; 3) making data more available in real-time at the point of contact and enabling the use of certified Electronic Health Record (EHR) technology and other data sources to support care delivery. 

Thank you again for the opportunity to share our perspective on this proposed rule. Please contact an AVAC Coalition Manager at (202) 540-1070 or lfoster@adultvaccinesnow.org if you wish to further discuss our comments. To learn more about the work of AVAC visit www.adultvaccinesnow.org. 

Sincerely, 

Lisa Foster, AVAC Manager
Abby Bownas, AVAC Manager 

AVAC Offers Comments on the Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program

AVAC managers sent a letter to the Centers for Medicare & Medicaid Services with comments on the Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program.

Centers for Medicare & Medicaid Services 
Department of Health and Human Services 
Attention: CMS-1748-P 
P.O. Box 8016 
Baltimore, MD 21244-8016 

To Whom It May Concern: 

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program. 

Specifically, AVAC wishes to highlight its strong support for the following proposals included in this proposed rulemaking: 

  • Efforts to close the Health Equity Gap and the opportunity to offer our views on important actions that are necessary to address longstanding disparities in adult immunization rates among minority and underserved populations. 
  • Adoption of a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure beginning With the FY 2023 IRF QRP 
  • Advancing Health Information Exchange through the development of quality measures and implementation of interoperability standards that will facilitate and improve immunization record reporting and real-time information sharing across health care providers, facilities and public health. 

AVAC consists of over 60 organizational leaders in health and public health that are committed to driving federal policy changes that will strengthen and enhance access to adult vaccines and awareness of the importance of adult immunization. AVAC works towards common legislative and regulatory solutions through 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. 

Closing the Health Equity Gap – RFI 

AVAC appreciates the opportunity to respond to the request for information on closing the health equity gap included in the proposed rule. Even before the COVID-19 pandemic, vaccine preventable illness devastated the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine-preventable diseases while adult coverage has lagged behind Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography. 

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have eroded further, leaving communities vulnerable to preventable disease, illness, and outbreaks.2 An analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.4 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates).5 Long-standing health disparities are also laid bare in these trends. Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 vaccine compared to 53% of white Americans.7 Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population.8 These trends could have serious consequences for the future, threatening widespread outbreaks of vaccine preventable conditions. We are grateful for CMS’ commitment to addressing systemic inequities that have resulted in poor health outcomes for certain populations. 

First, AVAC urges to CMS to promote dissemination and adoption of the National Vaccine Advisory Committee (NVAC) Standards for Adult Immunization Practice1. This standard of practice for immunizations would ensure that Medicare beneficiaries have equitable access to information about recommended vaccines and the opportunity to receive those vaccines from a trusted health care provider. Assessment of immunization status through adoption of NVAC adult standards of care and implementation of adult Immunization status measure is a vital component to addressing longstanding disparities in access to immunization and will ensure that all Medicare beneficiaries receive a strong immunization recommendation from their provider and have the resources they need to make an informed decision. Widespread implementation of the NVAC Standards for Adult Immunization Practice is also an important first step toward advancing the Healthy People 2030 

developmental measure to increase the proportion of adults age 19 or older who get recommended vaccines (IID-D03).2 

Another important element to closing the equity gap is consistent data collection and real-time reporting. The COVID-19 pandemic has illustrated the need for investments in our nationwide immunization data framework, as well as the dissemination and adoption of federal guidelines and incentives to encourage consistent reporting and widespread utilization of immunization information systems (IIS) across provider settings. In order to effectively identify and address health equity gaps, there must be strong and clear criteria in place for data reporting elements, provider usage, along with baseline standards interoperability, bidirectional exchange, data quality and security. AVAC encourages CMS to work with the HHS Office of Disease Prevention and Health Promotion to include the Healthy People 2030 lifespan IIS reporting3 developmental measure in its strategy to close equity gaps for adult immunization. Robust immunization record data reporting will empower providers, patients and caregivers to make educated decisions about vaccinations, reduce missed opportunities for immunization and minimize the likelihood of overvaccination, and help inform health care system efforts to close health equity gaps and prevent disease outbreaks. 

Lastly, AVAC also expresses support for the use of Quality Improvement Networks and Quality Improvement Organizations (QIN-QIOs) as a means to address the core priority areas outlined in the CMS Equity Plan for Improving Quality in Medicare. The three priority areas which inform CMS policies and programs are: (1) Increasing understanding and awareness of health disparities; (2) developing and disseminating solutions to achieve health equity; and (3) implementing sustainable actions to achieve health equity.4 The QIN-QIOs have a demonstrated track record of success in testing and evaluating innovative and effective strategies for improving immunization coverage rates among targeted Medicare populations.5 AVAC encourages CMS to continue to utilize the QIN-QIOs for this purpose and urges CMS to include in the list of tasks outlined in future scopes of work (SOW) strategies to improve immunization coverage rates among hard to reach rural and geographically underserved areas as well as among disabled, homebound, inpatient and congregate care patient populations. 

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure 

AVAC also appreciates the opportunity to express its strong support for CMS’ proposal to add a new COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to the FY 2023 SNF QRP. The COVID-19 pandemic had a disproportionate and devastating impact on older adults living in long-term care and congregate care settings. This new measure would 

require SNFs to report on COVID-19 HCP vaccination in order to assess whether SNFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of IRFs to continue serving their communities throughout the COVID-19 PHE and beyond. Under this proposal, IRFs would report the vaccination data through the Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) beginning October 1, 2021. 

AVAC believes this measure is vitally important to protect the health and wellbeing of older adults in IRFs and reporting of this measure through the NHSN helps to ensure transparency and accountability in community infection prevention and control efforts and is consistent with other HCP vaccination measures intended to preserve health and mitigate infectious disease outbreaks in long-term care settings. We know from reporting of influenza vaccination coverage of HCPs that provider uptake of the vaccine is also associated with that provider recommending vaccination to patients and encourages greater patient vaccination uptake. HCP vaccination can also potentially reduce illness-related missed work and disruptions to patient care. Lastly, reporting of HCP vaccination rates helps inform patients and caregiver choice when considering facilities from which to seek care, particularly for those at high-risk for developing serious complications from COVID–19. While data on the effectiveness of COVID–19 vaccines to prevent asymptomatic infection or transmission is limited, AVAC believes the COVID-19 HCP vaccination measure should nonetheless be included as part of efforts to assess and reduce the risk of transmission of COVID–19 within IRFs and urges CMS to maintain this proposal in the final rule. 

Fast Healthcare Interoperability Resources (FHIR) in support of Digital Quality Measurement in Quality Reporting Programs – RFI 

AVAC appreciates the work of the Department of Health and Human Services to “encourage and support the adoption of interoperable health information technology and to promote nationwide health information exchange to improve health care and patient access to their health information.” Promoting the use of consistent patient data sets across health care settings can be vitally important to ensure quality patient care and health outcomes while reducing the reporting burden on providers. Additionally, timely and accurate reporting of immunization record data is also of great importance for public health disease surveillance and outbreak prevention activities. Consistent data collection and reporting is a foundational element for successful quality measurement, transparency, and accountability. 

AVAC fully supports greater use of electronic clinical quality measures (ecQMs) across health care programs managed by HHS, including the Centers for Medicare and Medicaid Services (CMS), the Health Resources and Services 

Administration (HRSA), among other agencies. As CMS seeks feedback on definitions for digital quality measures (dQMs) for the IRF Quality Reporting Program (QRP), we would encourage CMS to look to existing ecQM resources that are available through the National Coordinator for Health Information Technology6 and as well as uniform data system modernization efforts within the Bureau of Primary Health Care at HRSA.7 Greater consistency in the adoption and use of electronic quality measures and a common reporting standard8across HHS programs that serve vulnerable populations of all ages and across health care settings will improve overall quality of patient care, drive better health outcomes, as well as inform and empower patients, without creating an additional complexities and reporting burdens on health care providers. 

In terms of vaccine data for patients in SNF and long-term care settings, AVAC supports incentivizing interoperable and bidirectional immunization data reporting to immunization information systems, leveraging tools and measures through the IRF QRP. As previously stated, provider, patient and caregiver access to immunization record data is essential to addressing health inequities in immunization coverage for the COVID-19, as well as the range of routinely recommended vaccines important to protecting the health and wellbeing of Medicare beneficiaries in long-term care and IRF settings. 

Quality measurement programs through Medicare play a critical role in promoting improved quality and encouraging adherence to and consistent utilization of recommended health care interventions, including adult vaccines. Vaccines play a vital role in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. The Department of Health and Human Services (HHS) recognizes that immunization is an important tool to keep people healthy and reduce avoidable health care costs across the lifecourse, especially given the COVID-19 pandemic and annual flu seasons. 

Thank you again for the opportunity to share our perspective on this proposed rule. Please contact an AVAC Coalition Manager at (202) 540-1070 or lfoster@adultvaccinesnow.org if you wish to further discuss our comments. To learn more about the work of AVAC visit www.adultvaccinesnow.org. 

Sincerely, 

Lisa Foster, AVAC Manager
Abby Bownas, AVAC Manager 

AVAC Offers Comments on the FY 2022 Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Updates

AVAC managers submitted a letter to the Centers for Medicare and Medicaid outlining areas of support and offering comments for several proposals under the proposed rulemaking for the Medicare program FY 2022 Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Updates for Fiscal Year Beginning October 1, 2021.

Centers for Medicare & Medicaid Services 
Department of Health and Human Services 
Attention: CMS-1750-P 
P.O. Box 8010 
Baltimore, MD 21244-8016  

To Whom It May Concern: 

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on Medicare Program: FY 2022 Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Updates for Fiscal Year Beginning October 1, 2021 

Specifically, AVAC wishes to highlight its strong support for the following proposals included in this proposed rulemaking: 

  • Efforts to close the Health Equity Gap and the opportunity to offer our views on important actions that are necessary to address longstanding disparities in adult immunization rates among minority and underserved populations. 
  • Adoption of a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure. 
  • Maintaining the Influenza Immunization (NQF #1659) and urges consideration of the Adult Immunization Status (AIS) measure in future rulemaking on IPFQR measures. 

AVAC consists of over 60 organizational leaders in health and public health that are committed to driving federal policy changes that will strengthen and enhance access to adult vaccines and awareness of the importance of adult immunization. AVAC works towards common legislative and regulatory solutions through 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. 

Closing the Health Equity Gap – RFI 

AVAC appreciates the opportunity to respond to the request for information on closing the health equity gap included in the proposed rule. Even before the COVID-19 pandemic, vaccine preventable illness devastated 

the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine-preventable diseases while adult coverage has lagged behind Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography. 

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have eroded further, leaving communities vulnerable to preventable disease, illness, and outbreaks.2 An analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.4 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates).5 Long-standing health disparities are also laid bare in these trends. Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 vaccine compared to 53% of white Americans.7 Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population.8 These trends could have serious consequences for the future, threatening widespread outbreaks of vaccine preventable conditions. We are grateful for CMS’ commitment to addressing systemic inequities that have resulted in poor health outcomes for certain populations. 

First, AVAC urges to CMS to promote dissemination and adoption of the National Vaccine Advisory Committee (NVAC) Standards for Adult Immunization Practice1. This standard of practice for immunizations would ensure that Medicare beneficiaries have equitable access to information about recommended vaccines and the opportunity to receive those vaccines from a trusted health care provider. Assessment of immunization status through adoption of NVAC adult standards of care and implementation of adult Immunization status measure is a vital component to addressing longstanding disparities in access to immunization and will ensure that all Medicare beneficiaries receive a strong immunization recommendation from their provider and have the resources they need to make an informed decision. Widespread implementation of the NVAC Standards for Adult Immunization Practice is also an important first step toward advancing the Healthy People 2030 developmental measure to increase the proportion of adults age 19 or older who get recommended vaccines (IID-D03).2 

Another important element to closing the equity gap is consistent data collection and real-time reporting. The COVID-19 pandemic has illustrated the 

need for investments in our nationwide immunization data framework, as well as the dissemination and adoption of federal guidelines and incentives to encourage consistent reporting and widespread utilization of immunization information systems (IIS) across provider settings. In order to effectively identify and address health equity gaps, there must be strong and clear criteria in place for data reporting elements, provider usage, along with baseline standards interoperability, bidirectional exchange, data quality and security. AVAC encourages CMS to work with the HHS Office of Disease Prevention and Health Promotion to include the Healthy People 2030 lifespan IIS reporting3 developmental measure in its strategy to close equity gaps for adult immunization. Robust immunization record data reporting will empower providers, patients and caregivers to make educated decisions about vaccinations, reduce missed opportunities for immunization and minimize the likelihood of overvaccination, and help inform health care system efforts to close health equity gaps and prevent disease outbreaks. 

Lastly, AVAC also expresses support for the use of Quality Improvement Networks and Quality Improvement Organizations (QIN-QIOs) as a means to address the core priority areas outlined in the CMS Equity Plan for Improving Quality in Medicare. The three priority areas which inform CMS policies and programs are: (1) Increasing understanding and awareness of health disparities; (2) developing and disseminating solutions to achieve health equity; and (3) implementing sustainable actions to achieve health equity.4 The QIN-QIOs have a demonstrated track record of success in testing and evaluating innovative and effective strategies for improving immunization coverage rates among targeted Medicare populations.5 AVAC encourages CMS to continue to utilize the QIN-QIOs for this purpose and urges CMS to include in the list of tasks outlined in future scopes of work (SOW) strategies to improve immunization coverage rates among hard to reach rural and geographically underserved areas as well as among disabled, homebound, inpatient and congregate care patient populations. 

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure 

AVAC also appreciates the opportunity to express its strong support for CMS’ proposal to add a new COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to the FY 2023 SNF QRP. The COVID-19 pandemic had a disproportionate and devastating impact on older adults. This new measure would require IPFs to report on COVID-19 HCP vaccination in order to assess whether IPFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of IPFs to continue serving their communities throughout the COVID-19 PHE and beyond. Under this proposal, IPFs would report the vaccination data 

through the Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) beginning October 1, 2021. 

AVAC believes this measure is vitally important to protect the health and wellbeing of Medicare beneficiaries in IPFs and reporting of this measure through the NHSN helps to ensure transparency and accountability in community infection prevention and control efforts and is consistent with other HCP vaccination measures intended to preserve health and mitigate infectious disease outbreaks. We know from reporting of influenza vaccination coverage of HCPs that provider uptake of the vaccine is also associated with that provider recommending vaccination to patients and encourages greater patient vaccination uptake. HCP vaccination can also potentially reduce illness-related missed work and disruptions to patient care. Lastly, reporting of HCP vaccination rates helps inform patients and caregiver choice when considering facilities from which to seek care, particularly for those at high-risk for developing serious complications from COVID–19. While data on the effectiveness of COVID–19 vaccines to prevent asymptomatic infection or transmission is limited, AVAC believes the COVID-19 HCP vaccination measure should nonetheless be included as part of efforts to assess and reduce the risk of transmission of COVID–19 within IPFs and urges CMS to maintain this proposal in the final rule. 

IPF Quality Reporting Program (IPFQRP) Immunization measures 

AVAC appreciates the proposed rule maintains Influenza Immunization (NQF #1659) for the Inpatient Psychiatric Facilities (IPF) Quality Reporting Program prescribed in the rule. AVAC urges CMS to maintain the measure in the final rule. Quality measures play a critical role in the CMS Quality Strategy as well as the National Quality Strategy in terms of influenza immunization efforts. The Department of Health and Human Services Strategic Plan FY 2018 –2022, encourages the use of age-appropriate vaccines to minimize the burden of vaccine-preventable diseases across the life span4. Quality measurement programs through Medicare promote improved quality and encourage adherence to and consistent utilization of recommended health care interventions, including adult vaccines. 

Vaccines play a vital role in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. The Department of Health and Human Services (HHS) recognizes that immunization is an important tool to keep people healthy and reduce avoidable health care costs across the lifecourse, especially given the COVID-19 pandemic and annual flu seasons. Maintenance of the Influenza Immunization measure will help protect lives, prevents morbidity and mortality and saves health care costs. 

In future rulemaking, AVAC urges CMS to consider inclusion of an Adult Immunization Status (AIS) measure in the IPFQRP. The AIS measure is a composite of several age-recommended vaccines for adults, comprising influenza, pneumococcal, zoster, and Tdap vaccines. Adoption of the composite measure aligns with CMS efforts to improve the quality of patient care, the overall patient experience and health outcomes. It would also provide a sound, reliable and comprehensive means to assesses the receipt of routinely recommended adult immunizations vital to healthy aging and prevention of avoidable illness. The AIS would reduce the reporting burden on providers while also incentivizing them to follow the National Vaccine Advisory Committee (NVAC) Practice Standards for Adult Immunization Practice1 to assess, recommend, administer or refer and document the vaccines the patient may (or may not) have received. 

Several years ago, AVAC released a White Paper outlining the value and imperative of quality measures for adult vaccines.2 The report highlights the role of vaccine quality measures in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. Quality measurement programs through Medicare play a critical role in promoting improved quality and encouraging adherence to and consistent utilization of recommended adult vaccines. 

The addition of an AIS quality measure to the IPFQRP would meet the three core strategies underlying the movement toward a truly patient-centered health care delivery system by: 1) Improving the way clinicians are paid to incentivize quality and value of care over simply quantity of services; 2) improving the way care is delivered by providing clinical practice support, data and feedback reports to guide improvement and better decision-making and; 3) making data more available in real-time at the point of contact and enabling the use of certified Electronic Health Record (EHR) technology and other data sources to support care delivery. 

Thank you again for the opportunity to share our perspective on this proposed rule. Please contact an AVAC Coalition Manager at (202) 540-1070 or lfoster@adultvaccinesnow.org if you wish to further discuss our comments. To learn more about the work of AVAC visit www.adultvaccinesnow.org. 

Sincerely, 

Lisa Foster, AVAC Manager
Abby Bownas, AVAC Manager 

AVAC Leads a Letter in Support of the Protecting Seniors Through Immunization Act

AVAC led over 80 stakeholders in sending a letter to Congress urging support of the Protecting Seniors Through Immunization Act (S.912/H.R.1978), a bill that helps strengthen vaccine uptake by improving education and equitable access to recommended vaccines for Medicare beneficiaries.

May 27, 2021 

Dear Majority Leader Schumer, Speaker Pelosi, and Minority Leaders McConnell and McCarthy: 

During Older Americans Month, we, the undersigned organizations that care about healthy aging, write to offer our strong support for the Protecting Seniors Through Immunization Act (S. 912/H.R. 1978). This bipartisan, bicameral legislation, led by Senators Hirono, Capito, Whitehouse, and Scott, and Representatives Kuster and Bucshon is especially important in the wake of coronavirus public health crisis. 

Prior to the COVID-19 pandemic, more than 50,000 adults died from vaccine-preventable diseases each year. Millions more suffer the health effects of those diseases, causing them to miss work to care for themselves or others and leaving them unable to engage in their routine activities. The COVID-19 pandemic has exacerbated this, causing adults to delay or avoid interactions with the health care system for preventative services. A component of combatting COVID-19 is a wider adoption of preventive health strategies to reduce the burden of co-morbid conditions that put people at higher risk of worse outcomes of COVID-19. Immunizing against all vaccine-preventable diseases will both contribute to better health outcomes overall and preserve vital capacity at hospitals by reducing preventable admissions. Despite the well-known benefits of immunization, adult coverage lagged behind federal targets for most commonly recommended vaccines. 

The Protecting Seniors Through Immunization Act will help strengthen vaccine uptake by improving education and equitable access to recommended vaccines for Medicare beneficiaries. It will bring much needed parity to the out-of-pocket payment required of Medicare beneficiaries for vaccines covered under Part B and Part D. Copayments apply only to vaccines covered under Medicare Part D (tetanus-diphtheria-acellular pertussis (Tdap) and varicella zoster (shingles)), and vary widely across plans. Immunizations should be available with no cost to the beneficiary in the same way vaccines are covered under Part B (Covid-19, flu, pneumococcal). Removing this barrier will provide a direct financial and health benefit for people age 65 and over and will help to improve our national preparedness among the Medicare population. 

Thank you for your consideration of support. 

Sincerely, 

Adult Vaccine Access Coalition 

Alliance for Aging Research 

Alliance for Immunizations in Michigan 

Alliance for Patient Access 

American Academy of Family Physicians 

American Association of Occupational Health Nurses (AAOHN) 

American Behcet’s Disease Association (ABDA) 

American College of Preventive Medicine (ACPM) 

American Federation of State, County and Municipal Employees (AFSCME) 

American Immunization Registry Association (AIRA) 

American Kidney Fund 

American Lung Association 

American Pharmacists Association (APhA) 

American Public Health Association (APHA) 

American Society on Aging 

Answer2Cancer 

Association of Asian Pacific Community Health Organizations (AAPCHO) 

Association of Immunization Managers (AIM) 

Association for Professionals in Infection Control and Epidemiology (APIC) 

Asian & Pacific Islander American Health Forum (APIAHF) 

AstraZeneca 

Biotechnology Innovation Organization (BIO) 

California Immunization Coalition 

CancerCare 

Caregiver Action Network 

Caring Ambassadors Program 

Coalition of Wisconsin Aging and Health Groups 

COPD Foundation 

Dynavax 

Families Fighting Flu 

Generations United 

Geriatric Medicine Pas 

Global Healthy Living Foundation 

GSK 

HealthHIV 

HealthyWomen 

Hep B United 

Hepatitis B Foundation 

Idaho Immunization Clinic 

Immunization Action Coalition (IAC) 

Immunize Colorado 

Immunize Nevada 

Immunize Ohio 

ImmunizeTN 

Infectious Diseases Society of America (IDSA) 

Justice in Aging 

KelseyCare Advantage 

Kelsey-Seybold Clinic Clinic 

Kimberly Coffey Foundation 

Lupus and Allied Diseases Association, Inc. 

Lupus Foundation of America 

Medical University of South Carolina 

Medicago 

Merck 

Moderna 

National Association of County and City Health Officials (NACCHO) 

National Association of Nutrition and Aging Services Programs (NANASP) 

National Black Nurses Association (NBNA) 

National Caucus and Center on Black Aging 

National Coalition for LGBT Health 

National Consumers League 

National Council of Asian Pacific Islander Physicians (NCAPIP) 

National Education Association (NEA) 

National Foundation for Infectious Diseases (NFID) 

National Grange 

National Hispanic Medical Association (NHMA) 

National Viral Hepatitis Roundtable (NVHR) 

Novavax 

Patient Access Network (PAN) Foundation 

Pfizer 

Physician Assistants in Hospice and Palliative Medicine (PAHPM) 

Pennsylvania Immunization Coalition 

RetireSafe 

Sanofi 

Scientific Technologies Corporation (STC) 

Service Employees International Union (SEIU) 

The AIDS Institute 

The Arizona Partnership for Immunization 

The Gerontological Society of America (GSA) 

The Immunization Partnership 

Triage Cancer 

Trust for America’s Health 

Tulsa Area Immunization Coalition 

University of Pennsylvania 

Vaccinate Your Family 

Vaccine Ambassadors 

Valneva 

WomenHeart: The National Coalition for Women with Heart Disease 

Women Impacting Public Policy (WIPP) 

AVAC Supports the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act

AVAC wrote Senators Hassan and Cassidy to express strong support for their leadership on the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act. Vaccines are crucial for protecting mothers and their babies, yet many pregnant women remain unvaccinated. The Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act will both modernize and increase maternal vaccination rates among the perinatal population.

Dear Senators Hassan and Cassidy,

We write to express our strong support for the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act. We appreciate your leadership around modernizing and improving maternal immunization rates.

Since 2004, the Advisory Committee on Immunization Practices (ACIP) has issued recommendations on the importance of maternal immunization, and currently recommends that all pregnant women receive the influenza, tetanus toxoid, reduced diphtheria toxoid, and acellular pertussis (Tdap) vaccines. Unfortunately, a recent survey by the Centers for Disease Control and Prevention (CDC) found that “many pregnant women are unvaccinated, and they and their babies continue to be vulnerable to influenza and pertussis infection and potentially serious complications including hospitalization and death.”

Pregnant women seeking access to and coverage for vaccines encounter multiple barriers, including lack of information about recommended vaccines, financial hurdles, and technological and logistical obstacles. Additionally, vaccine confidence and hesitancy issues remain a challenge. Your legislation seeks to change this and would help improve access to and utilization of maternal vaccines by ensuring first dollar coverage of vaccines for perinatal women enrolled in Medicaid; adopting the recent prenatal immunization quality measure; and requesting much sought-after data on obstetric patients and providers.

As immunizations are a highly cost-effective form of preventive medicine that help save lives by protecting the health and wellbeing of individuals and families in communities nationwide, it is in our nation’s interest to improve immunization coverage rates as a means to improve maternal health outcomes. With several promising new vaccines in the research pipeline for life threatening conditions that could provide important health benefits to pregnant women and their children, now is the time to focus on improving immunization rates in the perinatal population. 

Again, thank you for leadership on the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act. Members of AVAC stand ready to work with you on this, and other important and effective solutions around vaccines.

Sincerely,

AIDS Alliance for Women, Infants, Children, Youth & Families
American Immunization Registry Association
American Lung Association
American Public Health Association
Asian & Pacific Islander American Health Forum
Association of Asian Pacific Community Health Organizations (AAPCHO)
Association for Professionals in Infection Control and Epidemiology
Association of Maternal & Child Health Programs
Biondvax pharmaceuticals
Biotechnology Innovation Organization
Families Fighting Flu
GSK
Hep B United
Hepatitis B Foundation
Immunization Action Coalition
Infectious Diseases Society of America
Kimberly Coffey Foundation
March of Dimes
National Consumers League
National Foundation for Infectious Diseases
STChealth LLC
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family
WomenHeart: The National Coalition for Women with Heart Disease 

 

AVAC Urges Senate to Support Full Funding of Immunization-Related Activities at the Department of Health and Human Services.

AVAC sent a letter to Senate members asking for $1.13 billion for immunization-related activities at the Department of Health and Human Services as part of the fiscal year (FY) 2022 Labor, Health and Human Services (LHHS), and Education Appropriations bill. This investment would strengthen the immunization infrastructure, vaccinate against COVID-19, and restore vaccination rates for routine immunizations back to pre-pandemic levels.

March 10, 2021

Dear Chairwoman Murray and Ranking Member Blunt,

As members of the Adult Vaccine Access Coalition (AVAC), we write to ask for full funding of immunization-related activities at the Department of Health and Human Services as part of the fiscal year (FY) 2022 Labor, Health and Human Services (LHHS), and Education Appropriations bill.

The COVID-19 pandemic has reminded us of the importance of fully funding immunization efforts. Vaccines help us mitigate diseases, prevent severe illnesses, and reduce rates of hospitalization, morbidity, and mortality. The COVID-19 pandemic has taken a catastrophic toll on our society. The rollout of safe and effective coronavirus vaccines signals a light at the end of the tunnel but there are still important steps that Congress needs to take to ensure success of the nation’s COVID-19 vaccine distribution plan. The pandemic has also introduced new challenges to our health care system that have resulted in a significant reduction in routine vaccination rates across the life course.

It is critical that the LHHS appropriations bill includes sustainable funding for immunization efforts, including long-term investments in immunization infrastructure, including immunization information systems, vaccine confidence campaigns, and support for health care providers. Immunizations are a sound investment because they are a highly cost-effective form of preventive medicine that help save lives by protecting the health and wellbeing of individuals and families in communities nationwide. Vaccines not only help protect the immunized person but they can also help protect those around them who may not be able to be immunized because they are too young to be vaccinated or suffer from a health condition that prevents them from being immunized. We ask the Committee to strongly support the following programs in the FY22 LHHS bill:

$1.13 billion for the National Immunization Program at the Centers for Disease Control and Prevention (CDC)’s National Center for Immunization and Respiratory Diseases (NCIRD) (+$400m). The immunization program at CDC provides funding to state and local health departments to carry out a variety of activities vital to the prevention, detection, and mitigation of vaccine-preventable conditions. These essential grants are utilized not only for the purchase of vaccines, but also support a number of other important infrastructure activities, including: surveillance, safety and effectiveness studies, education and outreach, implementation of evidence-based community interventions to increase immunization coverage among underserved and high-risk populations, and vaccine-preventable disease outbreak response. The resources provided under the immunization program are vital to communities across the country, many of whom rely solely on these funds to support their immunization activities.

The work of the immunization program has become even more necessary as part of the sustained COVID-19 vaccination campaign. However, COVID-19 has also exposed weaknesses in the immunization infrastructure, including a lack of adult data in the immunization information systems (IIS), vaccine hesitancy, and disparities in vaccination rates. On top of the COVID-19 pandemic, disease outbreaks – including measles, Hepatitis A, and Hepatitis B—are on the rise and investments must be made to restore vaccination rates for routine immunizations back to pre-pandemic levels.

Fortunately, most health departments already have infrastructure in place but it is imperative that Congress invest in modernizing and take steps to sustain these important investments even once the immediate threats of the pandemic. Providing $1.13 Billion in FY22 will go a long way to strengthen the immunization infrastructure, vaccinate against COVID-19, and to restore vaccination rates for routine immunizations back to pre-pandemic levels.

$241 million for Influenza Planning and Response at CDC’s NCIRD (+$40m).

CDC’s Influenza Planning and Response programs help to protect the United States from seasonal influenza and pandemic influenza. Each winter, influenza causes millions of illnesses and hundreds of thousands of hospitalizations. The 2017-2018 season was especially dangerous with an estimated 61,000 Americans having died from influenza and its complications. During the 2018-2019 season, an estimated 35.5 million people got sick with influenza and 34,200 people died. Providing $241 million for the program will ensure CDC has the resources necessary to address the continual threats posed by seasonal and pandemic influenza.

$134 million for CDC’s Division of Viral Hepatitis (+$94.5m).

In 2021, the National Viral Hepatitis Strategic Plan called for the elimination of hepatitis A, B, and C as public health threats in the United States. There is currently a large-scale outbreak of HAV, resulting in an 850% increase in cases1. HAV and HBV have a safe and highly effective vaccine that can prevent infection. Yet only 25% of adults are vaccinated for HBV, representing a lost opportunity to prevent HBV infection. Chronic HBV requires life-long medical care, as there is no cure. Providing $134 million to expand adoption of CDC/United States Preventive Services Task Force (USPSTF) recommendations for HBV and HCV testing, HBV vaccination, and linkage to care.

$10 million for the National Vaccine Program within the Office of Infectious Disease and HIV/AIDS Policy (OIDP).

The National Vaccine Program at HHS provides strategic leadership and coordination of vaccine and immunization activities among federal agencies and other stakeholders whose mandate is to help reduce the burden of preventable infectious disease. This portfolio includes the National Vaccine Plan and National Vaccine Advisory Committee. Providing a $10 Million investment will be especially important for the work this office does around vaccine equity, confidence and safety. These funds will be essential in securing future implementation of the National Vaccine Strategic Plan, a comprehensive roadmap in the development and use of vaccines across the life course in the United States.

Now more than ever, sustained and predictable, funding for the CDC immunization programs is vital, to help combat the COVID-19 pandemic, to increase routine vaccination rates and to prepare for future pandemics. We look forward to working with your office as the FY22 appropriations process gets underway. For further information, please contact the AVAC managers at info@adultvaccinesnow.org.

Sincerely,

Alliance for Aging Research
American Academy of Family Physicians
American College of Preventive Medicine
American Heart Association
American Immunization Registry Association
American Pharmacists Association
American Public Health Association
Asian & Pacific Islander American Health Forum
Association for Professionals in Infection Control and Epidemiology
Association of Asian Pacific Community Health Organizations (AAPCHO)
Association of Immunization Managers
Association of Maternal & Child Health Programs
Association of Occupational Health Nurses
Association of State and Territorial Health Officials
Biotechnology Innovation Organization
Dynavax
Families Fighting Flu
GSK
Hep B United
Hepatitis B Foundation
Hepatitis Education Project
Immunization Action Coalition
Immunization Coalition of Washington, DC
Infectious Diseases Society of America
Johnson & Johnson
March of Dimes
Medicago
Merck
Moderna
National Association of City and County Health Officials
National Association of Nutrition and Aging Services Programs (NANASP)
National Black Nurses Association
National Consumers League
National Foundation for Infectious Diseases
National Hispanic Medical Association
National Minority Quality Forum
National Viral Hepatitis Roundtable
Novavax
Pfizer
Seqirus
STC Health
Takeda Vaccines
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family
WomenHeart: The National Coalition for Women with Heart Disease

AVAC Makes Recommendations to the Biden Administration on Immunization Infrastructure Systems (IIS)

AVAC sent a letter to the White House with recommendations on how best to implement the $7.5 billion provided to immunization infrastructure through the American Rescue Plan. The letter outlined guidance from the IIS Modernization Act (H.R. 550) to help the administration meet the challenge of tracking and administering COVID-19 vaccinations.

Dear President Biden, 

The COVID-19 pandemic has taken a devastating toll on our society. With more than 400,000 American lives lost, millions of people forced to file for unemployment, and too many children falling behind in school during online instruction. As the national strategy for the efficient, effective, and equitable distribution of the COVID-19 vaccines moves forward, immunization data systems are proving to be a critical tool in the success of this effort. 

We were pleased to see the American Rescue Plan Act of 2021 includes robust support for immunization infrastructure, including $7.5 billion for activities to plan, prepare for, promote, distribute, administer, monitor, and track COVID–19 vaccines. We wish to build upon the directive to provide technical assistance, guidance, and support to, and award grants or cooperative agreements to, State, local, Tribal, and territorial public health departments for enhancement of COVID–19 vaccine distribution and administration capabilities. Specifically, we wish to highlight the importance of “information technology, data, and reporting enhancements, including improvements necessary to support sharing of data related to vaccine distribution and vaccinations and systems that enhance vaccine safety, effectiveness, and uptake, particularly among underserved populations.” 

While most health departments have immunization infrastructure in place, they need an infusion of support now to operationalize pandemic immunization efforts. Immunization information systems (IIS) are computerized, multi-faceted systems that operate in 62 jurisdictions, and have the ability to maintain immunization records across the lifespan. They can be used by providers to order vaccines and track inventory, view patients’ previous vaccine to ensure they are fully vaccinated but not over-vaccinated, remind patients when they are due to receive a recommended vaccine, and, at a population level, track coverage and identify areas where there are low immunization rates so public health programs can develop targeted immunization efforts in response. 

We know for instance that race/ethnicity is known for just over half (55%) of people who had received at least one dose of the vaccine. Among this group, nearly two thirds were White (63%), 9% were Hispanic, 6% were Black, 5% were Asian, 2% were American Indian or Alaska Native, and <1% were Native Hawaiian or Other Pacific Islander, while nearly 14% reported multiple or other race. Under the President’s January 20th executive order to “Advance Racial Equity and Support for Underserved Communities through the Federal Government, it should not be simply enough to understand the trends when with proper investment we can pinpoint the individuals in communities of color that aren’t being served and take action to serve them. 

However, IIS capabilities today vary vastly across states and many systems desperately need support to meet the challenges of a Covid-19 mass vaccination campaign, especially to track coverage and identify areas where there are low immunization rates so public health programs can develop targeted immunization efforts in response. Without investments in immunization infrastructure – IIS in particular – the racial and geographic disparities in vaccination take-up are hard to track and eradicate. 

We ask that you look to the framework set out in the “IIS Modernization Act, H.R. 550” for additional guidance on how to enhance systems to manage “routine” immunization efforts and outbreaks of other vaccine preventable diseases. Among other things, the bill would authorize funding for the following activities: 

  • An assessment of current capabilities and gaps among immunization providers; 
  • Expand enrollment and training of immunization providers; 
  • Support real-time immunization record data exchange and reporting; 
  • Improve secure data collection, transmission, bidirectional exchange, maintenance, and analysis of immunization information; 
  • Enhance security of bidirectional exchange of immunization record data and interoperability of immunization information systems with health information technology platforms; and 
  • Enhance data exchange interoperability with other jurisdictions. 

We recommend the Administration to use these funds to improve, enhance, and expand the ability of IIS to securely exchange real-time immunization record data between federal health agencies, state, local, tribal, and territorial public health programs and providers across health care settings. Again, thank you for your consideration. 

Sincerely,

American Academy of Family Physicians
American Heart Association
American Lung Association
American Public Health Association
BIO
Dynavax
Families Fighting Flu
GSK
Hepatitis B Foundation/Hep B United
Immunization Action Coalition
Medicago
Merck
Moderna
National Consumers League
National Hispanic Medical Association
Sanofi
STChealth LLC
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family

AVAC Puts Forward Recommendations on the Biden Administration’s Vaccine Confidence Campaigns

AVAC supports the allotment of $1 billion from the American Rescue Plan for vaccine confidence campaigns; however, we encourage the Biden Administration to expand the CDC’s Vaccinate with Confidence Campaign to include all age groups. Doing so will build greater trust in recommended vaccines to increase routine vaccination rates in the long term.

Dear President Biden,

 

Thank you for your continued efforts to end the COVID-19 pandemic, strengthen vaccine confidence, and improve vaccination rates throughout the United States. We appreciate that the American Rescue Plan Act of 2021 dedicates $1 billion to build vaccine confidence, support vaccine education, and improve vaccination rates for COVID-19 vaccines as well as other vaccine preventable diseases (Section 3002).

 

As the COVID-19 pandemic continues to afflict individuals, families, and communities across the country, there is newfound attention on the importance of vaccines as an effective preventive health measure.1 Vaccines have always been one of greatest public health achievements, but especially in the midst of the pandemic, where there is overlap between populations that are vulnerable to the COVID-19, and other vaccine preventable disease.

 

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have plummeted–leaving communities vulnerable to preventable disease, illness, and outbreaks.2 Data indicate up to a 26% drop for MMR, DTap, and Polio vaccines between January and September of 2020.3 Another analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.4 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates).5 Long-standing health disparities are also laid bare in these trends. For example, emerging data shows traditionally underserved populations, such as those who are insured through Medicaid, have not only seen the greatest decline in routine vaccination rates but are also are recovering at a slower rate compared to those with private insurance.6 Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 compared to 53% of white Americans.7 Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population.8 Additionally, data on Asian American, Native Hawaiian, and Pacific Islander (AANHPI) populations is currently lacking and needs to be included in all aspects of COVID and public health. 

 

Recognizing these concerning trends and challenges could have serious consequences for the future, threatening to reverse decades of progress in achieving vaccine equity,9,10 the American Rescue Plan Act of 2021 targets funds to build vaccine confidence, support vaccine education, and improve vaccination rates for COVID-19 vaccines as well as other vaccine preventable diseases. To ensure disparate communities do not become even more vulnerable to preventable illnesses, outbreaks and death11 we ask that you expand CDCs Vaccinate with Confidence campaign12 to include all age groups – children, adolescents and adults. A sustained federal effort aimed at improving trust in recommended vaccines across the lifecourse and the systems that administer them—is essential to overcoming vaccine hesitancy and increasing acceptance of vaccines.13,14 We specifically recommend:

  • Building the trust that patients, their families, and providers have in recommended vaccines. This includes expand education and outreach, with a focus on sustained partnerships with trusted community messengers on the importance of recommended vaccines. This includes targeted vaccination campaigns to areas where people are least likely to be reached by traditional health care infrastructure and where there are known pockets of vaccine hesitancy. Furthermore, we urge CDC to expand upon community level grants and resources to enable local leaders to test and tailor proactive messages, while countering anti-vaccination sentiments.
  • Building trust for providers who administer vaccines. Efforts must seek to simultaneously educate and inform healthcare professionals (HCPs) to ensure they make a strong recommendation to patients, in order to raise awareness among patients regarding the need to receive all ACIP-recommended vaccinations and the alternative vaccination locations that may be available to them.
  • Helping communities understand and have confidence in the process and policies that lead to vaccine development, licensure or authorization, manufacturing, and recommendations for use.

Our country and public health infrastructure cannot afford to follow a pandemic with an increase in cases or large outbreaks of other vaccine preventable diseases. We are optimistic that this funding can support the ongoing work across the United States to not only recover from the pandemic but continue to protect our communities from vaccine preventable diseases and future outbreaks.

 

Sincerely,

 

American Academy of Family Physicians

American Heart Association

American Lung Association

American Public Health Association

Dynavax

Families Fighting Flu

GSK

Hepatitis B Foundation/Hep B United

Immunization Action Coalition

Medicago

Merck

Moderna

National Association of Nutrition and Aging Services Programs

National Consumers League

National Foundation for Infectious Diseases

National Hispanic Medical Association

Sanofi

STChealth LLC

The AIDS Institute

The Gerontological Society of America

Trust for America’s Health

Vaccinate Your Family

Vaxcare

AVAC Expresses Strong Support for the Helping Adults Protect Immunity Act

AVAC sent a letter to Senator Brown to show support for his leadership on the Helping Adults Protect Immunity (HAPI) Act, a bill that provides a baseline of consistent and reliable Medicaid coverage to ensure that all Medicaid enrollees do not face insurmountable financial hurdles when a recommended vaccine provides a clear and direct health benefit. 

Dear Senator Brown,

We write to express our strong support for the Helping Adults Protect Immunity (HAPI) Act. We appreciate your bi-cameral leadership to strengthen access to immunizations under Medicaid.

Medicaid, along with the Children’s Health Insurance Program (CHIP), is a federal-state insurance partnership that provides coverage to over 70 million low-income children and adults. Medicaid covers low-income older adults, persons with disabilities and chronic conditions, and pregnant women. Many of these same populations have been hit hard by the COVID-19 pandemic. These high-risk health groups are also extremely vulnerable to serious adverse health consequences of other vaccine preventable illnesses. Hospitalizations, increased morbidity and mortality, loss of independence, the ability to engage in activities of daily living, and reduced quality of life are but a few of the devastating, but avoidable, direct and indirect costs. Vaccine preventable conditions add over $8.3 billion to the health care system overall, according to a 2016 study of just four vaccine preventable conditions (influenza, pneumococcal disease, herpes zoster and pertussis).

The HAPI Act seeks to provide a baseline of consistent and reliable Medicaid coverage across the country. Currently, access to vaccines under Medicaid varies, depending on where you live and your Medicaid eligibility status. Medicaid enrollees who are covered through Medicaid expansion programs are guaranteed access to all vaccines recommended by the Advisory Committee on Immunization Practices (ACIP) with no cost sharing requirements. By contrast, not all vaccines recommended for adults are covered by traditional Medicaid programs and those that are covered may have cost sharing requirements that put access to the vaccine out of reach. The HAPI Act seeks to ensure that all Medicaid enrollees have access to this important preventive health service and do not face insurmountable financial hurdles when a recommended vaccine provides a clear and direct health benefit.

Again, thank you for leadership on the HAPI Act. Members of AVAC stand ready to work with you on this, and other important policy solutions, to strengthen and expand coverage for recommended vaccines to those who need it most.

Sincerely,

Alliance for Aging Research
American Academy of Family Physicians
Association for Professionals in Infection Control and Epidemiology
American Immunization Registry Association
American Lung Association
Association for Professionals in Infection Control and Epidemiology
Emily Stillman Foundation
Families Fighting Flu
GSK
Hepatitis B Foundation
Hep B United
Immunization Action Coalition
Infectious Diseases Society of America
Kimberly Coffey Foundation
Medicago
National Association of Nutrition and Aging Services Programs (NANASP)
National Black Nurses Association
National Viral Hepatitis Roundtable
STChealth
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family
WomenHeart: The National Coalition for Women with Heart Disease

AVAC Urges the Biden Administration to use its Presidential Budget to Tackle Vaccination Barriers

AVAC members offered comments on the need for the Biden Administration to address financial burdens brought about by vaccines, particularly those for adults, by allocating the necessary funds in its Build Back Better Recovery Plan.

Dear President Biden 

As our nation undergoes a vaccination program that will be the greatest public health efforts of our generation, members of the Adult Vaccine Access Coalition (AVAC) and stakeholder partners ask that as you consider updating longstanding structural flaws in our vaccine policies as part of the Build Back Better Recovery plan. Inequities in coverage of vaccines across public and private programs, particularly for adults, has hindered our nation’s disease prevention efforts and put older adults and persons with chronic conditions needlessly at risk and is critical to expanding access to preventative health care services. 

Section 2713 of the Public Health Service Act (PHS Act) added by the Patient Protection and Affordable Care Act (ACA) removed cost-sharing and co-pays for vaccinations recommended by the Center for Disease Control and Prevention Advisory Committee on Immunization Practices (ACIP) for all compliant private plans. However, Medicare and some Medicaid beneficiaries were left out of this change and still face high out-of-pocket costs for vaccinations. Financial barriers to all ACIP recommended vaccines must be eliminated for individuals covered by Medicaid and Medicare to improve the underlying health of the communities most at risk for COVID-19 and aid the elimination of racial disparities in health care. A fully vaccinated public is an investment in our future health, wellbeing and economic success of our national. Eliminating financial barriers thus is imperative and we urge you to tackle this issue in the President’s forthcoming Budget Proposal by including budget proposals that would remedy this disparity. 

Immunizations are a cornerstone of our nation’s disease prevention efforts and have a demonstrated track record of success as a cost-effective means of reducing disease burden and saving lives. Despite the well-known benefits of immunization, adult coverage lags behind federal targets for most commonly recommended vaccines: influenza, pneumococcal, tetanus, hepatitis B, herpes zoster, and HPV. Millions more adults suffer from vaccine-preventable diseases, causing them to miss work and leaving some unable to care for those who depend on them. Adults seeking access to and coverage for vaccines encounter multiple barriers, including lack of awareness and information about recommended vaccines, financial hurdles including high-cost sharing, as well as technological and logistical obstacles. Improving adult access to vaccines can save thousands of lives and billions of dollars. The health care costs associated with low adult vaccine rates are high—each year, the U.S. spends $26.5 billion treating four vaccine-preventable diseases (Flu, Pneumococcal, Shingles, Pertussis).

Medicare

Vaccines are particularly important for older adults because our immune systems weaken with time. Adults age 50 and over are particularly susceptible to many vaccine-preventable diseases and account for a disproportionate number of the deaths and illnesses they cause. This is why older adults are most at risk of developing severe illness from coronavirus. For older adults, many of whom live on fixed incomes, additional costs may delay or even prevent them from getting vaccinated. A 2018 study of Tdap and herpes zoster vaccine claims under Medicare Part D demonstrated that when the costs of vaccines are high, seniors can’t or won’t get them. The study found that costs of $51 or more to the beneficiary are associated with a greater rate of cancelled vaccination claims compared to beneficiaries with no out-of-pocket costs. We ask that you include the Protecting Seniors Through Immunization Act2, bicameral, bipartisan legislation which would ensure all vaccines under Medicare are available to beneficiaries with no cost sharing or deductibles as part of your budget proposal to Congress. The bill brings parity between out-pocket costs between Medicare Part B and Medicare Part D. 

Medicaid 

Currently, access to vaccines under Medicaid varies, depending on where live and your Medicaid eligibility status. Medicaid enrollees who are covered through Medicaid expansion programs are guaranteed access to all vaccines ACIP-recommended by the with no cost sharing requirements. By contrast, not all vaccines recommended for adults are covered by traditional Medicaid programs and those that are covered may have cost sharing requirements that put access to the vaccine out of reach. We must fix disparities in coverage in the Medicaid program by providing a baseline of consistent and reliable Medicaid coverage across the country. Medicaid covers low-income older adults, persons with disabilities and chronic conditions, and pregnant women. Many of these same populations have been hit hard by the COVID-19 pandemic. These high-risk groups are also extremely vulnerable to serious adverse health consequences of other vaccine preventable illnesses. We ask that you also include in the budget the Helping Adults Protect Immunity (HAPI) Act3, which would ensure that all Medicaid enrollees have access to this important preventive health service and do not face insurmountable financial hurdles when a recommended vaccine provides a clear and direct health benefit. 

As our country continues to work to meet the challenges of the pandemic, now is the time to redouble our efforts to eliminate the underlying vaccination disparities that have been prevalent in our health care system for too long. Our organizations are available to answer your questions at your earliest convenience. Please reach out to AVAC Managers Abby Bownas, (abownas@nvgllc.com) or Lisa Foster (lfoster@nvgllc.com). 

Sincerely,
 
American Academy of Family Physicians 
American Lung Association 
American Public Health Association 
BIO 
Dynavax 
Families Fighting Flu 
GSK 
Hepatitis B Foundation/Hep B United 
Immunization Action Coalition 
Medicago 
Moderna 
National Association of Nutrition and Aging Services Programs 
National Consumers League 
National Hispanic Medical Association 
National Minority Quality Forum 
Sanofi 
STChealth LLC 
The AIDS Institute 
The Gerontological Society of America 
Vaccinate Your Family 
Vaxcare