AVAC Responds to HHS’s Value-Based Transformation Initiative

AVAC responded to HHS’s request for information regarding Secretary Azar’s Value-Based Transformation PreventionX Initiative. In the letter, AVAC recommends that models or proposals targeting chronically ill patients that are developed through the PreventionX initiative include immunization, a proven and effective methods of primary prevention.

December 20, 2019

Ed Simcox
HHS Chief Technology Officer
U.S. Department of Health & Human Services 200 Independence Ave. SW
Washington, DC 20201

RE: Request for Information – PreventionX

Dear Mr. Simcox,

On behalf of the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to share our thoughts in response to the Department of Health and Human Services Chief Technology Officer Request for Information with respect to Secretary Azar’s Value-Based Transformation Initiative. We share the Secretary’s goal of moving towards a health care system focused on rewarding and improving patient outcomes, not only on reimbursement for procedures. In this vein, AVAC recommends that models or proposals targeting chronically ill patients that are developed through the PreventionX initiative include immunization, a proven and effective methods of primary prevention.

AVAC consists of over 55 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 and utilization of adult immunizations.

AVAC strongly agrees with the argument raised in the request for information regarding, “the misalignment of incentives in the health system that account for some of the current gap between the science of prevention and its implementation. Both public and private payers currently devote considerably fewer resources to prevention than they do to treatment—despite the fact that investments in prevention offer greater potential value, as measured by lower total costs of care and improved health outcomes.”

Nowhere is the misalignment and lack of investment more evident than immunization. Despite advances in immunization coverage, adult vaccine rates fall far below federal goals. Numerous barriers to access remain and the current design of the health care system does not reward providers, health systems and plans for prioritizing immunization services, especially in the context of caring for patients with chronic illness. However, these are patients are precisely the ones at greatest risk of experiencing significant adverse health outcomes as a result of a vaccine preventable illness.

For instance, individuals with heart disease, lung disease, and diabetes are at increased risk of flu-related complications and exacerbation of underlying disease, even when the conditions are well-managed. It is estimated that 31% of US adults age 50-64 years and 47% of those age 65 years and older have at least one chronic health condition that puts them at high risk for flu-related complications, including hospitalization, catastrophic disability, and even death. In fact, 90% of flu-related deaths and the majority of flu-related hospitalizations occur in older adults—the individuals most likely to be living with chronic health conditions.

28 million Americans have heart disease and are at 6 times greater risk of heart attack within a week of having the flu. Recent research shows a direct correlation between influenza vaccination and lower risk for cardiovascular events such as heart attack and stroke. 1 Getting immunized against the flu prevents secondary complications and can be just as effective as other interventions as smoking cessation, statins, or anti- hypertensive therapy in preventing major coronary events. The data is similar in terms of increased risk of hospitalization and morbidity and mortality in patients with diabetes and lung disease.

In the “Dangers of Influenza and Benefits of Vaccination in Adults with Chronic Health Conditions,” subject matter experts call out strategies to protect vulnerable populations must emphasize the benefits of vaccination to overall health, mitigation of illness severity and complications, and improved patient outcomes. Additionally, in October 2019, several leading patient organizations joined together to issue an alert to raise awareness around the importance of getting immunized against the flu. Similarly, the American Lung Association launched My Shot campaign that features individual patient stories on the importance of getting immunized against the flu. Pneumonia, hepatitis B and shingles also present greater risks of serious health consequences in patients living with chronic illness.

While the scope of the RFI does not currently include infectious disease, please keep in mind the critically important role immunization plays in protecting the health and wellbeing of the chronically ill. By prioritizing this cost-effective intervention, we can cultivate more active and healthier aging populations, reduce the risk of disability, loss of mobility, and independence, and protect patients with chronic conditions.

Thank you again for this opportunity to offer our views to this RFI. As a next step, members of AVAC would appreciate the chance to meet with you, or your staff to share more information and best practices on how immunization can improve the health and wellbeing of the millions of Americans with or at risk of chronic conditions. Should you have questions, please or would like additional information please contact AVAC Managers Abby Bownas (abownas@nvgllc.com) or Lisa Foster (lfoster@nvgllc.com).


Alliance for Aging Research
Asian & Pacific Islander American Health Forum Hep B United
Hepatitis B Foundation Immunization Action Network
National Association of County and City Health Officials
National Association of Nutrition and Aging Services Programs (NANASP) National Consumers League
National Foundation for Infectious Diseases National Viral Hepatitis Roundtable STChealth
Trust for America’s Health


Blackburn R, et al. Clin Infec Dis. 2018;67:8-17.

Nguyen JL, et al. JAMA Cardiol 2016; 1:274–81.

Kwong JC, et al, N Engl J Med 2018; 378:345-353

MacIntyre CR, et al. Heart. 2016;102:1953-1956

Gozalo PL et al. J Am Geriatr Soc. 2012;60:1260-1267.