As members of in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the CMS proposed rule reforming the requirements for Long-Term Care Facilities.
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 targeted, evidence-based initiatives to improve adult immunization rates among minority, vulnerable, and at-risk populations, including people with chronic illness, limited English proficient speakers, and frail elderly in long-term care settings.
AVAC appreciates the inclusion of the proposal to require long-term care facilities to develop and implement policies and procedures to ensure residents and/or their representatives receive education on benefits and potential side effects of influenza and pneumococcal vaccination, and document the resident’s consequent immunization status (received vaccine, contraindicated, or refused) in the patient’s medical record. Long-term care facility residents, especially those with chronic conditions, are at increased risk for influenza-related complications such as pneumonia, making immunization particularly important for patient health and safety.
The draft HHS National Adult Immunization Plan states that, “[a]lthough education alone is insufficient to increase vaccination rates, it can have significant impact as a part of a number of broader, evidence-based strategies. Adults are often unaware of their potential risk of acquiring disease that can be prevented by vaccination and of the availability of specific vaccines. This lack of knowledge may be particularly acute among populations with limited English proficiency and persons with disabilities.” We believe directing long-term care facilities to provide education to patients and their representatives will improve informed decision making and will increase utilization of influenza and pneumococcal immunizations.
We also support the proposed elimination of the exception allowing healthcare providers to administer a second pneumococcal vaccine five years following the first since this is no longer considered the standard of care. 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 for use in long-term care settings. 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.2 AVAC encourages CMS to work with NQF since these this work reflects CMS’ broader goals around quality measure alignment.
We encourage CMS to act expeditiously in providing access to and coverage for new vaccines following ACIP recommendations. Patients in long-term care facilities are particularly vulnerable to vaccine preventable diseases and suffer disproportionate rates of morbidity and mortality as a result. Timely access to new and improved vaccines for a growing number of conditions will allow beneficiaries to enjoy the benefits of the growing arsenal of preventive tools to enable Medicare beneficiaries to live longer and healthier lives.
AVAC also appreciates the inclusion of a provision directing long-term care facilities to include immunizations in the patient data set that must be communicated by facilities when a patient is transferred from one health care institution to another. Tracking and monitoring a patient’s immunization status as they move from one part of the health care system to another is critical to ensuring that adults receive appropriate and timely immunization services. Accurate immunization information in a patient’s data set, along with demographic information, surgical history, medications, etc., helps to elevate the importance of immunizations as a part of a patient’s overall health care.
Lastly, we encourage CMS to provide a more detailed explanation behind the proposal to re-designate influenza and pneumococcal immunizations from infection control to pharmacy services. A further explanation of the rationale behind the proposed change as well as CMS’ expectations going forward would be beneficial for long-term care providers and managers of pharmacy services.
Thank you for the opportunity to offer our perspective on this proposed rule. Please contact the AVAC Coalition Manager Lisa Foster at (202) 540-1070 or firstname.lastname@example.org if you wish to discuss our comments or adult immunization issues.