As participants in the Adult Vaccine Access Coalition (AVAC), we are grateful for the opportunity to offer our comments on Measures under Consideration by the Measure Applications Partnership (MAP) at the National Quality Forum (NQF).

AVAC consists of more than 40 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.

We appreciate NQF’s leadership in the area of adult vaccines, particularly the August 2014 report, “Priority Setting for Healthcare Performance Measurement: Addressing Performance Measure Gaps for Adult Immunizations.” One of AVAC’s key coalition priorities is to advocate for federal benchmarks and measures to encourage health plans to track, report and achieve increased adult immunization rates.  We believe the vaccine related measures under MAP consideration make progress toward closing the measure gaps identified in the report.

First, we commend NQF for considering process measures for Medicare beneficiaries with liver diseases, including Hepatitis A and Hepatitis B measures for cirrhosis patients (MUC15-210 and MUC15-211) and Hep B vaccination for patients with chronic Hepatitis C (MUC15-220), as well as a flu vaccine measure for end stage renal disease (ESRD) patients (MUC15-761).

Our coalition strongly believes that consistent and improved access to the range of Advisory Committee on Immunization Practices (ACIP) recommended vaccines for adults will result in improved health outcomes and better quality of life for Medicare beneficiaries.  As such, the vaccine process measures under consideration by NQF for the MIPS build upon core immunization measures currently employed by CMS under the Physician Quality Reporting System (PQRS). We urge NQF to continue its work with CMS to ensure that the core set of immunization process measures included in the Medicare Incentive Payment System (MIPS) are up-to-date and reflect current ACIP recommendations.  We also encourage NQF to continue to identify, develop and test immunization process measures that will improve the overall health for Medicare patients living with other chronic conditions such as heart disease and diabetes under the new MIPS.

Additionally, we support the inclusion of MUC15-1132, Percent of Skilled Nursing Facility Residents Who Were Assessed and Appropriately Given the Influenza Vaccine.  This important process measure complements and reinforces CMS’ efforts to improve education and awareness of long-term care facility residents and their representatives of the risks and benefits of immunization against a variety of preventable conditions1.  Long-term care facility residents, especially those with chronic conditions, are at increased risk for influenza and disproportionately suffer from influenza-related complications such as pneumonia, making immunization particularly important for patient health and safety.

We would also encourage NQF to prioritize the development of an updated pneumococcal immunization measures that reflects the current Advisory Committee for Immunization Practice (ACIP) recommendations for PCV13 and PPSV23 vaccination in adults age 65 and older as well as at risk adults ages 19-64 for use across various health 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.  AVAC encourages NQF to work with CMS toward that end since it reflects CMS’ broader goals around quality measure alignment.

Lastly, we would ask NQF to further coordinate with CMS and prioritize the identification, development testing and endorsement of vaccine measures for application by other CMS programs in addition to the ones listed for 2015.  For example, the recently finalized CMS rule on Medicare home health value-based purchasing includes a new measure entitled, “Herpes Zoster (Shingles) Vaccination: Has the Patient Ever Received the Shingles Vaccination?)2. Zoster vaccination measurement was identified as an age-specific gap priority in NQF’s August 2014 adult immunization measure gap report3.  Shingles affects a million Americans each year, half of whom are adults age 60 and older.  This extremely debilitating condition takes a significant toll on Medicare beneficiaries’ health and quality of life and also costs millions in health care dollars annually.

Thank you for your work to advance health and wellbeing through your stewardship and leadership in quality measure identification, development and deployment.  We greatly appreciate the opportunity to share our perspective on the vaccine related process measures currently under consideration.  Should you have any questions or would like to discuss our comments or adult immunization issues, please contact the AVAC Coalition Manager at (202) 540-1070 or info@adultvaccinesnow.org.