January 10, 2022
Office of Disease Prevention and Health Promotion
U.S. Department of Health and Human Services
1101 Wootton Parkway, Suite
420, Rockville, MD 20852
Dear Director Blakey,
Members of the Adult Vaccine Access Coalition (AVAC) and stakeholder partners, we appreciate the opportunity to offer comments on Healthy People 2030 and make recommendations to ensure that it reflects current public health priorities. As a stakeholder coalition interested in improving the health and wellbeing of adults through better access to immunization services, we value the work happening around implementation of Healthy People 2030 and the opportunity to comment on newly proposed objectives as well as offer recommendations on new additional core measures. AVAC would propose that two current developmental measures be adopted as core objectives, specifically the adult immunization status (AIS) and the life course Immunization Information Systems (IIS) measures.
AVAC includes more than sixty-five organizational leaders in health and public health who are committed to addressing barriers to adult immunization. AVAC works toward regulatory and legislative solutions that will strengthen and enhance access to adult immunization across the healthcare system. Our mission is informed by 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. A top priority for AVAC is to achieve increased adult immunization rates by encouraging compliance with federal benchmarks and performance measures that encourage utilization of recommended vaccines.
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. Since the Healthy People initiative began in 1979, there has been tremendous progress with respect to improved childhood immunization rates – one of the greatest public health achievements of the 20th century. Vaccine programs have contributed to the elimination of polio in the US and have dramatically reduced the spread of many more crippling and potentially life-threatening diseases such as diphtheria, tetanus, measles, mumps, and rubella. Vaccines also prevent the spread of common infectious and potentially fatal diseases such as chickenpox, influenza, hepatitis A, hepatitis B, meningococcal disease, pneumococcal disease, and whooping cough (pertussis). Vaccines not only help protect the immunized person but also those around them who may not be able to be immunized because they are too young to be vaccinated themselves or suffer from a health condition that prevents them from being immunized. When immunity levels in the population are high, the infectious agents do not circulate, which is known as herd immunity. Maintaining herd immunity is essential to protecting and preserving the health and wellbeing of individuals and entire communities from vaccine preventable conditions.
Prior to the pandemic, more than 50,000 adults were dying each year from vaccine preventable diseases and thousands more suffered serious health problems. Despite Advisory Committee for Immunization Practices (ACIP) recommendations, vaccines are underutilized in the adult population for the most commonly recommended vaccines (influenza, pneumococcal, Tdap, hepatitis B, herpes zoster, human papillomavirus (HPV,) and meningococcal vaccines). At least 3 out of every 4 adults are missing one or more routinely recommended vaccines. Disparities are even greater among at-risk populations, including seniors and people with chronic illness, as well as racial and ethnic underserved populations. Given the recognized health benefits of adult vaccinations and low rates of adult vaccination, made worse by the COVID-19 pandemic, coupled with the aging of the U.S. population, the impact of vaccine preventable conditions and their complications in adults is only expected to grow, with significant implications for the economy and society. Adult immunization is a core preventive health intervention that supports healthy aging and helps to avoid the costly effects of vaccine preventable illness. It is therefore imperative that as a nation we remain focused on improving adult vaccination rates.
Over the past several decades, the Healthy People immunization and infectious disease objectives have been a cornerstone to national efforts to protect against vaccine preventable conditions across the lifespan. For example, as part of HP2020, the goal for flu vaccine coverage for adults 18 and over was 70% but the actual rate was closer to 45%, while the goal for pneumococcal vaccine coverage was 60% but the actual rate was closer to 25%. Healthy People objectives help to guide the actions of public and private stakeholders across the country who are committed to improving the health and wellbeing of our nation and provide a foundation for measuring progress.
AVAC was disappointed when the initial slate of proposed Immunization and Infectious Disease (IID) objectives for Healthy People 2030 (HP2030) eliminated many critical immunization objectives, including Shingles, Pneumococcal, and Hepatitis vaccination. Recognizing that removing immunization objectives, at a time when vaccine preventable conditions were resurging in communities across the country and efforts to achieve HP2020 immunization goals for adults had largely stagnated, the final HP2030 included two developmental measures, including the Adult Immunization Status Measure (AIS) and a life course Immunization Information System (IIS) measure.
IID-D03. Increase the proportion of adults age 19 years or older who receive recommended age-appropriate vaccines
The Adult Immunization Status Measure (AIS) captures four immunizations in one (influenza, Td/Tdap, zoster and pneumococcal). Having an adult composite is very much in line with the Healthy People 2030 plan to set national goals and measurable, evidence-based objectives to guide federal, state and local policies, programs and other activities to improve health and well-being. It would complement similar composite core objectives for children and adolescent immunization status and build out a lifespan approach to federal immunization efforts. At the same time, it would align HP2030 objectives with external health care quality measurement tools, streamlining the patchwork of existing adult immunization measures, reducing the reporting burden to providers, and providing a meaningful national picture of access to this important preventive service. We urge HHS to initiate a process to transition this measure from a developmental to a core Immunization and Infectious Disease (IID) objective in 2022.
Recognizing that developmental measures are those categorized as “not yet having reliable baseline data,” we believe the AIS has a record for inclusion. As you know, the HHS National Vaccine Program Office (NVPO) and the CDC, in collaboration with the National Adult Immunization and Influenza Summit, developed and tested this composite measure based on one previously utilized by the Indian Health Service. In November 2021, it was included for adoption by health plans in the Healthcare Effectiveness Data and Information Set (HEDIS), one of healthcare’s most widely used performance improvement tools. With an estimated 26 million doses of recommended vaccines missed during pandemic1, now is the time to implement this important AIS measure and help our health care providers take steps necessary to ensure that adult patients are fully immunized and have maximum protection from serious disease by assessing immunization status at every clinical encounter and making a strong recommendation for vaccines needed; administering needed vaccines or referring to a provider who can immunize; and, document vaccines administered or received in the immunization information system (IIS).
IID-D02. Increase the proportion of immunization information systems that track adult immunizations across the lifespan
Immunization Information Systems (IIS) are confidential systems that are an essential part of the immunization infrastructure. IIS play a critical role in creating a comprehensive consolidated immunization record, assisting with vaccine evaluation, and forecasting, generating patient reminders, assessing vaccine uptake, providing schools and childcare providers access to consolidated records, assisting with vaccine ordering and inventory management, supporting outbreak investigation, calculating vaccine coverage estimates, and much more. Improving IIS utilization can lead to increased vaccination rates, contributing to the overall goal of reducing vaccine preventable disease. Immunization providers rely on IIS to implement an increasingly complex vaccination schedule, as well as monitor vaccine safety, efficacy, and vaccine delivery. The broad availability of immunization data through real-time Electronic Health Record (EHR)-IIS query significantly lowers the burden (and cost) to providers in accessing immunization records and forecasts at the point of care.
Moving the lifespan IIS objective from the developmental to the core Immunization and Infectious Disease (IID) objective set will elevate the importance of immunization record capture for all individuals into an IIS as a national priority. At the same time, it can help to eliminate disparities by promoting more accurate evaluation of coverage gaps across the country. Since immunizations are a cornerstone for protecting the public’s health, and given the growing importance of health information technology, there should be a commitment to supporting the IIS reporting objective across the life course. We urge that IID-D02 be moved from developmental to reporting objective in 2022.
New Public Health Infrastructure Objectives
AVAC also would like to take a moment to express support for the two proposed objectives to improve public health infrastructure in tribal communities:
Public Health Infrastructure-NEW-08: Increase the proportion of tribal communities that have developed a health improvement plan. (Data source: Public Health in Indian Country Capacity Scan, National Indian Health Board)
Public Health Infrastructure-NEW-09: Increase the proportion of tribal public health agencies that use Core Competencies for Public Health Professionals in continuing education for personnel. (Data source: Public Health in Indian Country Capacity Scan (PHICCS), National Indian Health Board)
While these new objectives encompass more than just vaccination, AVAC believes they are important to improve health equity for tribal communities and strengthening of public health in these communities.
Again, thank you for this additional opportunity to comment on HP2030 and to offer our support for moving the AIS and IIS measures from developmental to core objectives as well as support for the proposed public health infrastructure objectives. AVAC believes the AIS and IIS objectives will help our nation to achieve and maintain a strong emphasis on vaccines as part of Healthy People 2030 federal health benchmark goals. We believe now is the time to make immunization coverage across the lifespan a shared national priority and goal that all stakeholders in the health care system should be striving for over the coming decade. Please contact the AVAC Coalition Managers at (202) 540-1070 or email@example.com if you wish to further discuss our comments. To learn more about the work of AVAC, visit www.adultvaccinesnow.org.
American Academy of Family Physicians
American Public Health Association
Asian & Pacific Islander American Health Forum
Association for Professionals in Infection Control and Epidemiology
Center for Sustainable Health Care Quality and Equity
Families Fighting Flu
Hep B United
Hepatitis B Foundation
Immunization Action Coalition
Immunization Coalition of Washington, DC
Merck & Co Inc.
National Association of County and City Health Officials
National Association of Nutrition and Aging Services Programs
National Consumers League
National Foundation for Infectious Diseases
National Viral Hepatitis Roundtable
Takeda Vaccines, Inc.
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family