To Representatives DeGette and Upton:

The Adult Vaccine Access Coalition (AVAC) appreciates the opportunity to provide feedback that will help shape and inform the development of 21^st Century Cures 2.0. We greatly appreciate your years of leadership in federal policymaking aimed at accelerating innovations in clinical research and trials as well as improving processes that will expediate access to breakthrough therapies, treatments, and technologies. We are also grateful that your draft legislation calls attention to the public health challenges that have become apparent over the course of the COVID-19 pandemic and offers some meaningful solutions.

AVAC consists of over 60 organizational leaders in health and public health that are committed to addressing 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 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 to and utilization of adult immunizations.

As you know, 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. Over the last decade, advancements in technology, policy, and infrastructure have strengthened the immunization landscape. However, the COVID-19 pandemic put a tremendous strain on our chronically underfunded public health infrastructure and exposed important weaknesses that simply must be addressed. We must apply the lessons learned and integrate best practices as we work together to ensure the tools and capabilities necessary to swiftly and confidently respond to future disease outbreaks, pandemics, or disasters are in place.

Section 104. Vaccine and Immunization Programs: We are incredibly grateful that the CURES 2.0 Act recognizes the need for additional resources to bolster immunization awareness efforts and infrastructure.  Specifically, the draft authorizes $25 million for an awareness campaign to educate the public with respect to the safety and importance of vaccines and an additional $25 million to strengthen immunization infrastructure systems (IIS). These resources for vitally important to the long-term success of COVID-19 vaccination efforts as well as routine immunization catch up activities that are necessary preserve and protect the health of individuals, families and entire communities.

AVAC urges you to consider also incorporating provisions included in bipartisan legislation, theImmunization Infrastructure Modernization Act (HR550).

While most health departments have immunization infrastructure in place, we learned during the pandemic that the data collection and reporting capabilities of these systems varied greatly. We must ensure that Immunization Information systems (IIS) can meet certain basic security, data collection and reporting standards if we are going to be able to have real-time reporting of reliable immunization information during the next disease outbreak or pandemic.

In addition to funding, Congress has an important leadership role to play in advancing a federal policy framework to help guide IIS modernization investments in terms of the capacity and breadth of these systems, as well as establishing clear goals, expectations and outcomes. As Congress continues to make investments in immunization information system modernization efforts, ensuring these systems can be relied upon to consistently collect and report accurate immunization record data securely and in real-time is essential not only for the next pandemic but also for routine immunization activities.

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 a patient’s vaccine history 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.

However, the pandemic laid bare the fact that IIS capabilities vary across states and many systems were in woefully need of modernization to adequately meet the challenges of a COVID-19 mass vaccination campaign. These systems are vital to public health efforts to track coverage and identify areas where there are low immunization rates so targeted immunization outreach and education efforts can be developed in response. Without investments in immunization infrastructure – IIS in particular – the racial and geographic disparities in vaccination take-up rates are hard to track and address.

We ask that you look to the framework set out in the “IIS Modernization Act, H.R. 550²” for added guidance on how to enhance systems to manage both routine immunization efforts and outbreaks of other vaccine preventable diseases. Among other things, the bill includes the following provisions:

• 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.

Section 402. Strategies to Increase Access to Telehealth under Medicaid and Children’s Health Insurance Program and Section 403. Extending Medicare Telehealth Flexibilities.

The CURES 2.0 Act takes important steps to advance policies to integrate telehealth into public health insurance programs. The provisions affirm the use of telehealth services and enable opportunities for additional health care providers and sites to utilize telehealth services in the provision of care. The COVID-19 pandemic accelerated the adoption of telehealth services and provided access to care at a time when in person visits were not possible. AVAC appreciates that your legislation seeks to preserve and expand upon the availability of telehealth services and the many flexibilities that were granted as a result of the public health emergency.

In terms of immunization, AVAC believes that telehealth services can be a valuable tool for primary care providers to conduct patient immunization status assessments and counseling, particularly for complex patients with chronic conditions. Allowing providers to utilize telemedicine to conduct patient outreach, counseling and education on the importance of recommended vaccines not only during pandemics and public health emergencies but also during the course of regular care will help drive improvements in immunization rates across the lifecourse. Emphasizing support for the provision of telehealth services by providers who care for underserved populations will also enable them to improve and expand immunization efforts within their practices.

Additionally, AVAC supports making vaccine regulatory flexibilities and authorities granted during the public health emergency permanent. Allowing for a wide diversity of health care providers and sites of care to offer vaccines enabled rapid deployment of COVID-19 vaccines to millions of Americans. AVAC urges you to consider including policies that created more access points across communities for immunization and assured health care providers that they would be compensated for vaccine services. We hope Congress will work to extend them beyond the pandemic and to routinely recommended vaccines. Inclusion in the CURES 2.0 Act would be an important step toward that goal.

AVAC appreciates your work and leadership on this important legislation and your consideration of our recommendations. We look forward to working with you throughout the legislative process and stand ready to serve as a resource as you advance this important bipartisan bill.