June 20, 2016
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1645-P
P.O. Box 8016
Baltimore, MD 21244-8016
Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities Proposed Rule for FY 2017, SNF Value-Based Purchasing Program, SNF Quality Reporting Program, and SNF Payment Models Research
To Whom It May Concern:
As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the Medicare Program proposed rule on the SNF Quality Reporting Program.
AVAC consists of over forty-five organizational leaders in health and public health that are committed to tackling the range of barriers to adult immunization and to raising awareness of and engaging in advocacy on the importance of adult immunization. Our mission is informed by a growing body of scientific and empirical evidence of the benefits of immunization through 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. A top priority for AVAC is to achieve increased adult immunization rates through federal benchmarks and measures that encourage tracking and reporting of recommended vaccines.
Vaccines protect us from a variety of common diseases that can be serious and even deadly. Every year, more than 50,000 adults die from vaccine preventable diseases and thousands more suffer serious health problems. Despite Advisory Committee for Immunization Practices (ACIP) recommendations, vaccines have been consistently underutilized in the adult population and lag far behind the Healthy People 2020 goals for the most commonly recommended vaccines (influenza, pneumococcal, Tdap, hepatitis B, herpes zoster, HPV). Disparities are even greater when looking at-risk populations, including seniors and people with chronic illness- many of the same vulnerable populations residing in skilled nursing facilities across the country.
The Skilled Nursing Facility Quality Reporting Program (SNF QRP) presents an important opportunity to promote higher quality and more efficient health care for Medicare beneficiaries. AVAC believes the SNF QRP should include a focused, concerted approach to adult immunizations as a means of improving the health of patients living in skilled nursing facilities.
AVAC appreciates the opportunity to respond to the request for comment on the importance, relevance, appropriateness, and applicability for each of the quality measures in “Table 13” SNF QPR Quality Measures under consideration for future years. We support the development of a measure related to the IMPACT Act domain, as well as accurately communicating the existence of and providing for the transfer of health information and care preferences of an individual to the individual, family caregiver of the individual, and providers of services furnishing items and services to the individual, when the individual transitions. We support the addition of the National Quality Strategy Priority Measure related to health and well-being, Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine.
We further encourage CMS to consider prioritizing a broader set of recommended immunization measures as part of the SNF QRP. In this vein, we ask that CMS work with relevant stakeholders to develop, test, and integrate additional ACIP-recommended adult immunizations into quality measure and incentive benchmarks under Medicare SNF QRP Quality Measures. Immunization has demonstrated “effective prevention” in reducing rates of morbidity and mortality from a growing number of preventable conditions and has been proven to improve overall health in a cost efficient manner. Reducing the number of missed immunization opportunities is imperative to improving health and reducing the burden of vaccine preventable illness among the skilled nursing population.
Thank you for this opportunity to offer our perspective on this rule being considered. Please contact the AVAC Coalition Manager at 202 540 1070 or info@adultvaccinesnow.org if you wish to further discuss our comments. To learn more about the work of AVAC visit www.adultvaccinesnow.org.
Sincerely,
American College of Preventive Medicine
Asian Pacific Islander American Health Forum
Dynavax
Gerontological Society of America
Immunization Action Coalition
National Association of County and City Health Officials
Sanofi
Takeda
Trust for America’s Health