Letters Archive - Page 11 of 12 - Adult Vaccine Access Coalition

AVAC responds to the CMS National Coverage Analysis Comment Request on Hepatitis B Screening for High-Risk Medicare Beneficiaries

The revised United States Preventive Services Task Force (USPSTF) hepatitis B screening recommendations compliment long standing ACIP recommendations for hepatitis B vaccination and will further advance efforts to identify those with chronic HBV and link them to care. AVAC urged CMS to allow for access to hepatitis B screening as an “additional preventive service” in light of the new USPSTF evidence-based recommendations.

Letters to Administration

Quality Measures

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February 20, 2016

RE: Centers for Medicare and Medicaid National Coverage Analysis for Screening for Hepatitis B Virus (HBV) Infection (CAG-00447N)

Dear Ms. Jensen:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) National Coverage Analysis for hepatitis B screening for Medicare beneficiaries who are at high risk for hepatitis B (HBV) infection as defined by the United States Preventive Services Task Force (USPSTF).

AVAC consists of 45 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.

While up to 2 million Americans have chronic HBV infection, 67% are unaware of their condition, placing them at significant risk for advanced liver disease, liver cancer, and/or in need of a liver transplant. HBV is the leading cause of primary liver cancer (hepatocellular carcinoma, HCC), which is the 2nd deadliest cancer and remains the only cancer that continues to rise rising in both incidence and mortality among men and women in the U.S. According to the Centers for Disease Control and Prevention (CDC), “Hepatitis B vaccination is the most effective measure to prevent hepatitis B virus (HBV) infection and its consequences, including cirrhosis of the liver, liver cancer, liver failure, and death.”

In 2014, the USPSTF gave a grade of “B” for risk-based HBV screening, which includes those born in countries and regions with a high prevalence of HBV infection (>2%); people born in the U.S. who were not vaccinated as infants and whose parents were born in a region with high prevalence of hepatitis B infection (>8%); HIV-positive individuals; injection drug users; men who have sex with men and household partners and sexual partners of people who are HBV infected. ACIP recommendations issued as part of a comprehensive immunization strategy to eliminate transmission of Hepatitis B virus infection in the United States also identifies these target populations as being at high risk for the disease.

The revised USPSTF hepatitis B screening recommendations compliment long standing ACIP recommendations for hepatitis B vaccination and will further advance efforts to identify those with chronic HBV and link them to care. We urge CMS to allow for access to hepatitis B screening as an “additional preventive service” in light of the new USPSTF evidence-based recommendations. Of the identified and reported cases of HBV in the U.S. between 2007 and 2012, 15.6% were over the age of 65 and part of the Medicare covered population. Seniors who are Medicare beneficiaries and are unware of HBV infection are likely to have been living with the disease for a very long time and it is vital to ensure they are linked to care and treatment before they develop advanced liver disease or liver cancer.

AVAC supports including HBV screening under Medicare Preventive Services to improve identification of beneficiaries at high risk for the disease and improve health outcomes for these target populations. Thank you for the opportunity to offer our perspective. Please contact the AVAC Coalition Manager (202) 540-1070 or info@adultvaccinesnow.org if you wish to discuss our comments or adult immunization issues.

— Tamara Syrek Jensen, JD
Director, Coverage and Analysis Group Center for Clinical Standards and Quality Centers for Medicare & Medicaid Services

AVAC Issues Statement on the Release of the National Adult Immunization Plan

Laura Hanen and Phyllis Arthur, co-chairs of the Adult Vaccine Access Coalition (AVAC), issued the following statements regarding the release of the National Adult Immunization Plan from the U.S. Department of Health and Human Services’ National Vaccine Program Office (NVPO).

Letters to Administration

Benefits of Immunization Eliminating Disparities Reducing Financial Barriers

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The following are statements from Laura Hanen and Phyllis Arthur, co-chairs of the Adult Vaccine Access Coalition (AVAC), regarding the release of the National Adult Immunization Plan from the U.S. Department of Health and Human Services’ National Vaccine Program Office (NVPO).

“The Adult Vaccine Access Coalition (AVAC) congratulates NVPO on the release of the National Adult Immunization Plan. The plan is a roadmap to a healthier future where the life- and cost-saving potential of vaccines is affordable and accessible to all adults.

Childhood immunizations are one of the most remarkable public health success stories of our time, but we continue to lag far behind when it comes to adults. Every year, more than 50,000 adults in the United States die from vaccine preventable diseases and thousands more suffer serious health problems that recommended vaccines can prevent. While our nation has made important progress in recent years on eliminating barriers to and increasing awareness of vaccines, they remain beyond the reach of too many Americans—particularly minorities and the uninsured, for whom immunization rates are significantly lower on average than the general population.

As a diverse coalition of health care providers, vaccine manufacturers, pharmacies, and public health, patient, and consumer groups, AVAC is pleased that the report lays out targeted benchmarks to increase immunization rates among all adults that and puts forward solutions to strengthen the capacity of our public health infrastructure to meet those goals. We are eager to mobilize our members and work with federal agencies and other adult immunization coalitions to move this plan from paper to practice.

In the coming years, continued medical breakthroughs and technological advances will lead to the creation of new vaccines and improvements in those currently available. Implementation of the National Adult Immunization Plan will help ensure that every American—no matter their age, location, or socioeconomic status—will be able to reap the benefits. AVAC looks forward to working with our federal government partners on these efforts now and in the future.”

-Laura Hanen, Co-Chair of AVAC and the Chief of Government Affairs for the National Association of County and City Health Officials (NACCHO)

“The release of the National Adult Immunization Plan marks a seminal moment in the ongoing effort to bring more vaccines to more people. The Adult Vaccine Access Coalition (AVAC) was grateful for the opportunity to weigh in on the draft plan last year and is pleased that the final version reflects a number of our priorities.

One of AVAC’s key priorities is tackling the remaining systemic barriers to immunization. Thanks to the Affordable Care Act, millions of previously uninsured Americans now enjoy health coverage and access to recommended vaccines at no cost. But such protections are not available across the board. AVAC appreciates that the plan specifically shines a light on the predicament of Medicare beneficiaries who often have significant out-of-pocket costs associated with vaccines covered under Part D. We will continue to work closely with the Centers for Medicare and Medicaid Services to encourage Part D plans to eliminate patient cost-sharing requirements for recommended vaccines.

The plan notes that quality improvement initiatives are critical to ensuring meaningful progress on public health and prevention efforts. We share the plan’s vision of a system that includes immunizations as a core component of patients’ acute healthcare and preventive health services. Moreover, recent advancements in health information technology have the potential to significantly improve real-time monitoring of nationwide vaccine coverage while simultaneously tracking rates of diseases that recommended vaccines can prevent. Pinpointing areas where immunization rates are strong and where they can improve can facilitate targeted outreach to specific locations and among populations who need it most.

Successful implementation of the National Adult Immunization Plan will rest in large part on our commitment to several principles: educating all adults about the incredible benefits vaccines provide; making vaccines available to everyone, from all backgrounds; and simplifying the delivery process. These are the values on which AVAC was founded and they will inspire us to help make implementation of this plan a success.”

-Phyllis Arthur, Co-Chair of AVAC and the Managing Director for Infectious Diseases and Diagnostics Policy at the Biotechnology Innovation Organization (BIO)

AVAC Submits Comments on the HHS Notice of Benefit and Payment Parameters for 2017 Regarding Essential Community Providers and Network Adequacy

AVAC wrote to HHS to respond to the HHS Notice of Benefit and Payment Parameters for 2017 regarding Essential Community Providers and Network Adequacy. HHS has an opportunity and a duty to ensure that adult populations have access to primary care providers and pharmacists who are considered by qualified health plans (QHPs) to be essential community providers (ECP) for the purposes of vaccine information, education, and administration. AVAC urged HHS to consider disaggregating certain ECP categories in the 2017 benefit year to ensure better access to a range of providers licensed to provide immunization information, education and administration services within each plan’s service area. AVAC also urged HHS to include the range of health care professionals in the community who serve as immunizers (primary care providers and community pharmacists) to be included as a metric used to measure provider network adequacy for plans seeking to be considered as a QHP on the Health Insurance Exchanges.

Letters to Administration

Supporting Providers

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As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the HHS Notice of Benefit and Payment Parameters for 2017.

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.

The Affordable Care Act (ACA) enacted a set of reforms requiring health plans to cover vaccines recommended by ACIP without any cost-sharing requirements when provided by an in-network provider. This provides an opportunity for adults ages 19 years and older who are enrolled in a group or individual private health plan to fully access recommended vaccinations such as Hepatitis A, Hepatitis B, Herpes Zoster, Human Papillomavirus vaccine, Influenza, Measles, Mumps, Rubella, Meningococcal, Pneumococcal, Tetanus, Diphtheria, Pertussis, and Varicella.

As important to covering immunizations without any cost-sharing requirements, is ensuring that a robust network of community providers who are qualified to administer vaccines to adult populations is available and accessible.

Vaccines are a consistently underutilized yet valuable prevention tool. Despite efforts to expand access to the range of preventive services with no cost sharing to patients, adult immunization rates continue to lag far behind Healthy People 2020 goals. These disparities are even more pronounced with you consider at-risk populations, including seniors, communities of color, limited English proficient persons and people with chronic illness.

Essential Community Providers (ECPs), §156.235:
AVAC believes that HHS has an opportunity and a duty to ensure that adult populations have access to primary care providers and pharmacists who are considered by qualified health plans (QHPs) to be essential community providers for the purposes of vaccine information, education and administration. If health care consumers are to truly take advantage of the range of covered preventive health services that are available to them with no out of pocket cost, ECPs must be accessible within their communities. Health promotion and disease prevention efforts focused on encouraging broad based immunization against a range of vaccine preventable conditions, including influenza, pneumococcal, tetanus, shingles and hepatitis fall short when QHPs offer insufficient networks of participating practitioners serving as community immunizers to carry out this important work. AVAC urges HHS to consider disaggregating certain ECP categories in the 2017 benefit year to ensure better access to a range of providers licensed to provide immunization information, education and administration services within each plan’s service area.

Network Adequacy, §156.230:
Section 1311 (c)(1)(B) of the Affordable Care Act also established minimum criteria and standards for determining provider network adequacy for health plan qualification as a qualified health plan (QHP). AVAC urges HHS to include the range of health care professionals in the community who serve as immunizers (primary care providers and community pharmacists) to be included as a metric used to measure provider network adequacy for plans seeking to be considered as a QHP on the Health Insurance Exchanges. It is essential that HHS closely monitor the availability of this essential preventive service in communities across the country.

Thank you for the opportunity to offer our perspective on this proposed rule. Please contact the AVAC Coalition Manager (202) 540-1070 or info@adultvaccinesnow.org if you wish to discuss our comments or adult immunization issues.

AVAC Responds to the National Quality Forum (NQF) Measure Applications Partnership (MAP) Request for Comment on a List of Standardized Performance Measures

AVAC commended NQF for considering vaccine process measures for Medicare beneficiaries with liver diseases and for including MUC15-1132 (Percent of Skilled Nursing Facility Residents Who Were Assessed and Appropriately Given the Influenza Vaccine). AVAC also encouraged NQF to prioritize the development of an updated pneumococcal immunization measures that reflects the current Advisory Committee for Immunization Practice (ACIP) recommendations and asked 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.

Letters to Administration

Quality Measures

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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 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.

AVAC Responds to CMS Information Request on Adult Immunization Measures for New Merit Incentive Payment System (MIPS) for Physicians Under Medicare

AVAC sent comments to CMS on the development of Merit-based Incentive Payment System (MIPS) and Alternative Payment Models. AVAC asked CMS to consider including quality measures covering all ACIP recommended vaccines among CMS’ future measure selection and development process categories.

Letters to Administration

Quality Measures

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To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on this RFI on the development of Merit-based Incentive Payment System (MIPS) and Alternative Payment Models.

CMS has demonstrated leadership and a commitment to ensuring timely access to key vaccines recommended for adults by the Advisory Committee for Immunization Practices (ACIP). We commend your agency for its important work in this critical area of public health and prevention and urge you to continue to grow the number of recommended vaccines being measured under the MIPs. Section 1848 (q)(10) of the Act requires the Secretary to consult with stakeholders in carrying out the MIPS, including for the identification of measures and activities for each of the four performance categories under the MIPS. We strongly encourage you to work with the appropriate quality measure development organizations, provider groups and public health stakeholders to prioritize and advance the quality measures covering vaccine preventable disease.

a. Reporting Mechanisms Available for Quality Performance Category (p. 12)
The RFI asks if CMS should maintain the same or similar reporting criteria under MIPS as under Physician Quality Reporting System (PQRS) and what is the appropriate number of measures on which a MIPS eligible professional’s performance should be based. AVAC supports maintaining a core set of immunization measures from the PQRS as these measures are critical preventive services benchmarks. Monitoring immunization status and reporting of offered and administered immunizations to patients helps to ensure that the range of available immunizations remain a priority and in the forefront of clinical care standards. Reducing the number of missed immunization opportunities, particularly among Medicare beneficiaries, is critical to improving health and reducing the burden of vaccine preventable disease.

The RFI also asks if CMS should maintain the policy that measures cover a specified number of National Quality Strategy (NQS) domains. As you know, the 6 NQS domains are: 1) Patient and Family Engagement; 2) Patient Safety; 3) Care Coordination; 4) Population/Public Health; 5) Efficient Use of Healthcare Resources; 6) Clinical Process/Effectiveness. Immunization quality measures cover population/public health, efficient use of healthcare resources as well as the clinical process/effectiveness domains.

The RFI notes intent to develop a comprehensive set of quality measures to be available for widespread use under the MIPS and APS. CMS should consider including quality measures covering all ACIP recommended vaccines among CMS’ future measure selection and development process categories. CMS states that future quality measures could be aligned with the National Quality Strategy (NQS), the CMS Strategic Plan, and other CMS quality reporting and value-based purchasing programs. AVAC fully supports the alignment of reporting mechanisms and believes doing so will strengthen and enhance the development and implementation of adult immunization quality measures. Immunization is “effective prevention” in reducing rates of morbidity and mortality from a growing number of preventable conditions and has been demonstrated to improve overall health in a cost efficient manner.

Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine preventable diseases while adult coverage remains well below Healthy People 2020 targets for most commonly recommended vaccines (influenza, pneumococcal, Tdap, HepB, herpes zoster, HPV). Millions more adults suffer from vaccine-preventable diseases, causing them to miss work and leaving them unable to care for those who depend on them. Prioritizing immunization related quality measures would help identify coverage gaps, improve upon immunization rates and create greater health outcomes across adult populations.

Sincerely,

American Association of Occupational Health Nurses (AAOHN)
Asian & Pacific Islander American Health Forum (APIAHF)
Biotechnology Industry Organization (BIO)
GSK
Infectious Diseases Society of America (IDSA)
March of Dimes
National Association of County and City Health Officials (NACCHO)
Pfizer
Sanofi Pasteur
Takeda Pharmaceuticals
The Gerontological Society of America (GSA)
Trust for America’s Health (TFAH)

AVAC Commends CMS Efforts to Improve Patient Education and Access to Influenza and Pneumococcal Immunizations in Long-Term Care Facilities

AVAC offered comments on the CMS proposed rule reforming the requirements for Long-Term Care Facilities. AVAC expressed support for CMS’s proposal to require long-term care facilities to develop and implement policies and procedures to ensure residents receive education on benefits and potential side effects of influenza and pneumococcal vaccination, document the resident’s consequent immunization status in the patient’s medical record, and include immunizations in the patient data set that must be communicated by facilities when a patient is transferred from one health care institution to another. AVAC also supported the proposed elimination of the exception allowing healthcare providers to administer a second pneumococcal vaccine five years following the first since this is no longer considered the standard of care. Finally, AVAC asked CMS to provide a more detailed explanation behind the proposal to re-designate influenza and pneumococcal immunizations from infection control to pharmacy services.

Letters to Administration

Quality Measures

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As members of in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the CMS proposed rule reforming the requirements for Long-Term Care Facilities.

AVAC consists of more than 35 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.

AVAC 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. One of our key coalition priorities is to advocate for targeted, evidence-based initiatives to improve adult immunization rates among minority, vulnerable, and at-risk populations, including people with chronic illness, limited English proficient speakers, and frail elderly in long-term care settings.

AVAC appreciates the inclusion of the proposal to require long-term care facilities to develop and implement policies and procedures to ensure residents and/or their representatives receive education on benefits and potential side effects of influenza and pneumococcal vaccination, and document the resident’s consequent immunization status (received vaccine, contraindicated, or refused) in the patient’s medical record. Long-term care facility residents, especially those with chronic conditions, are at increased risk for influenza-related complications such as pneumonia, making immunization particularly important for patient health and safety.

The draft HHS National Adult Immunization Plan states that, “[a]lthough education alone is insufficient to increase vaccination rates, it can have significant impact as a part of a number of broader, evidence-based strategies. Adults are often unaware of their potential risk of acquiring disease that can be prevented by vaccination and of the availability of specific vaccines. This lack of knowledge may be particularly acute among populations with limited English proficiency and persons with disabilities.” We believe directing long-term care facilities to provide education to patients and their representatives will improve informed decision making and will increase utilization of influenza and pneumococcal immunizations.

We also support the proposed elimination of the exception allowing healthcare providers to administer a second pneumococcal vaccine five years following the first since this is no longer considered the standard of care. We encourage CMS to work with relevant stakeholders and quality measure organizations to develop an updated pneumococcal immunization measure that reflects the current Advisory Committee for Immunization Practice (ACIP) recommendation for PCV13 and PPSV23 vaccination in adults age 65 and older for use in long-term 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.2 AVAC encourages CMS to work with NQF since these this work reflects CMS’ broader goals around quality measure alignment.

We encourage CMS to act expeditiously in providing access to and coverage for new vaccines following ACIP recommendations. Patients in long-term care facilities are particularly vulnerable to vaccine preventable diseases and suffer disproportionate rates of morbidity and mortality as a result. Timely access to new and improved vaccines for a growing number of conditions will allow beneficiaries to enjoy the benefits of the growing arsenal of preventive tools to enable Medicare beneficiaries to live longer and healthier lives.

AVAC also appreciates the inclusion of a provision directing long-term care facilities to include immunizations in the patient data set that must be communicated by facilities when a patient is transferred from one health care institution to another. Tracking and monitoring a patient’s immunization status as they move from one part of the health care system to another is critical to ensuring that adults receive appropriate and timely immunization services. Accurate immunization information in a patient’s data set, along with demographic information, surgical history, medications, etc., helps to elevate the importance of immunizations as a part of a patient’s overall health care.

Lastly, we encourage CMS to provide a more detailed explanation behind the proposal to re-designate influenza and pneumococcal immunizations from infection control to pharmacy services. A further explanation of the rationale behind the proposed change as well as CMS’ expectations going forward would be beneficial for long-term care providers and managers of pharmacy services.

Thank you for the opportunity to offer our perspective on this proposed rule. Please contact the AVAC Coalition Manager Lisa Foster at (202) 540-1070 or info@adultvaccinesnow.org if you wish to discuss our comments or adult immunization issues.

AVAC Encourages CMS to Expand Upon Existing Adult Immunization Quality Measures in Physician Quality Reporting System Payment

AVAC appreciated the opportunity to comment on the fiscal year 2016 CMS Physician Fee Schedule and Other Revisions to Part B Proposed Rule. AVAC comments focused on the following topics: 1) retaining current immunization quality measures; 2) developing an updated pneumococcal measure to reflect current ACIP recommendations; 3) including additional immunization quality measures in the PQRS; and 4) increasing reimbursement for vaccine administration.

Letters to Administration

Quality Measures

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As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the fiscal year 2016 CMS Physician Fee Schedule and Other Revisions to Part B Proposed Rule.

AVAC 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. One of our key coalition priorities is to advocate for federal benchmarks and measures to encourage health plans to track, report and achieve increased adult immunization rates among subscribers. Our comments focus on the following topics: 1) retaining current immunization quality measures; 2) developing an updated pneumococcal measure to reflect current ACIP recommendations; 3) including additional immunization quality measures in the PQRS; and 4) increasing reimbursement for vaccine administration.

We commend CMS for maintaining a number of immunization measures in the Physician Quality Reporting System (PQRS) as these measures are critical preventive services benchmarks. Monitoring immunization status and reporting of offered and administered immunizations to patients helps to ensure that the range of available immunizations remain a priority and in the forefront of clinical care standards. Reducing the number of missed immunization opportunities, particularly among Medicare beneficiaries, is critical to improving health and reducing the burden of vaccine preventable disease.

In particular, we appreciate the retention of the Annual Influenza Vaccination (ACO #14) and the Pneumonia Vaccination Status for Older Adults measure (ACO #15) in the Medicare Shared Savings Program (MSSP’s) Preventive Health domain. These two measures are an important baseline for access to influenza and pneumococcal vaccination services and will help ensure protection against vaccine preventable conditions that exact a heavy toll on adults in terms of health and productivity costs.

The disproportionate burden of disease and the potential benefits of vaccination among adults make continued monitoring of immunization access and utilization a key priority. According to the Centers for Disease Control and Prevention (CDC), an estimated 900,000 Americans get pneumococcal pneumonia each year, resulting in as many as 400,000 hospitalizations and more than 53,000 deaths. Despite the fact that most pneumococcal pneumonia deaths each year are adults, 67 million adults at increased risk remain unvaccinated. By contrast, a recent CDC study of flu-associated deaths prevented over a nine year period from 2005-2006 through 2013-2014 found that nearly 89 percent were in people 65 years of age and older.

In the immediate term, we encourage CMS to work with relevant stakeholders and quality measure organizations to develop an updated pneumococcal immunization measure that reflects the current Advisory Committee for Immunization Practice (ACIP) recommendation for PCV13 and PPSV23 vaccination in adults age 65 and older as well as at risk adults 19-64 years old. 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.1 AVAC encourages CMS to work with NQF since these this work reflects CMS’ broader goals around quality measure alignment.

Such a measure could be incorporated in the measure sets for the multiple chronic conditions group as well as the diabetes measures group. Individuals with diabetes and multiple chronic conditions are at significantly higher risk of complications and death from pneumonia. According to the American Diabetes Association, people with diabetes are three times more likely to die with flu and pneumonia, yet only a third of people with diabetes receive a pneumococcal vaccination.

Similarly, AVAC recommends CMS also consider expanding the Influenza Immunization screening measure (NQF #0041) that is currently used in the multiple chronic conditions and diabetes measures groups and explore adding the Pneumonia Vaccination Status for Older Adults (NQF#0043) to the cardiovascular prevention measures group in the final rule. These two measures represent an important baseline for access to influenza and pneumococcal vaccination services and are being utilized effectively in other settings under the Medicare program. We believe they will greatly reduce the number of missed immunization opportunities for heart disease patients improve health and reduce the burden of vaccine preventable disease.

AVAC Comment Letter Encourages CMS to Move Forward with Adult Immunization Quality Measures Under New Home Health Value-Based Purchasing Model (HHVBP)

AVAC sent CMS comments on the CY 2016 Home Health Payment proposed rule, commending them for the inclusion of several adult immunization measures including the Influenza Immunization Received for Current Flu Season (NQF#0522) and for considering two new immunization process measures relating to influeza and shingles for study and inclusion in the HHVBP. AVAC also asked that CMS consider including an alternative measure for the Pneumococcal Polysaccharide Vaccine Ever Received (NQF#0525), such as Pneumonia Vaccination Status for Older Adults (NQF#0043), in the final rule because this measure no longer reflects current recommendations of the Advisory Committee on Immunization Practices (ACIP).

Letters to Administration

Quality Measures

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As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the CY 2016 CMS Home Health Payment Proposed Rule.

AVAC consists of more than 35 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.

AVAC commends CMS for including the Influenza Immunization Received for Current Flu Season (NQF#0522) and among the Population/Community Health measures proposed for adoption in the Home Health Value-Based Purchasing Model (HHVBP). We also appreciate that the proposed rule includes a Pneumococcal Polysaccharide Vaccine Ever Received (NQF#0525) but would note this measure no longer reflects current recommendations of the Advisory Committee on Immunization Practices (ACIP). AVAC urges CMS to consider including an alternative measure, such as Pneumonia Vaccination Status for Older Adults (NQF#0043) in the final rule.

These two measures represent an important baseline for access to influenza and pneumococcal vaccination services and are being utilized effectively in other settings under the Medicare program. We believe they will greatly enhance the ability of home health providers to monitor immunization status and report offered and administered influenza and pneumococcal immunizations to beneficiaries. Reducing the number of missed immunization opportunities among patients in the home health setting is critical to improving health and reducing the burden of vaccine preventable disease.

Looking ahead, we could note that the NQF report “Priority Setting for Healthcare Performance Measurement: Addressing Performance Measure Gaps for Adult Immunizations.”1 noted that 60 measures have been developed to address pneumococcal immunization and that to reduce the burden and improve the value of measurement, measures should be harmonized and consolidated and “at a minimum, all measures should be up to date with current ACIP/CDC recommendations.” To that goal, through its Health and Well-Being Standing Committee, NQF has proposed and approved standard specifications for pneumococcal vaccination to enable measure stewards for the existing measures (CMS and NCQA) to assess, and presumably modify, measures based on the revised standardized specifications.2

We encourage CMS to work with relevant stakeholders and quality measure organizations such as NQF to develop an updated pneumococcal immunization measure that reflects the current Advisory Committee for Immunization Practice (ACIP) recommendation for PCV13 and PPSV23 vaccination in adults age 65 and older as well as at risk adults 19-64 years old for inclusion in the HHVBP.

AVAC is also pleased that CMS is considering two new immunization process measures for study and inclusion in the HHVBP, Influenza Vaccination Coverage among Healthcare Personnel (NQF #0431) and Herpes Zoster (Shingles) Vaccination: Has the Patient Ever Received the Shingles Vaccination?”. As the proposed rule notes, NQF#0431 is already being utilized in a number of other health care settings.

Moreover, leading medical and health professional associations support influenza vaccination policies for healthcare professionals to help protect patients.3 Healthcare personnel are the first line of defense when it comes to preventing illness and preserving health. Measurement tools reflecting this priority are essential to promoting health and advancing prevention in the home health setting and AVAC strongly supports the inclusion of this measure in the final rule.

We greatly appreciate that CMS is also seeking to make herpes zoster vaccination a priority for the HHVBP. As the proposed rule notes, only 24.2 percent of adults age 60 and older reported receiving the herpes zoster vaccine, which falls short of the modest Healthy People 2020 target rate of 30 percent.4 The health and economic burden associated with shingles and its complications are significant. We commend CMS for recognizing that, “receiving the vaccine will often reduce the course and severity of the disease”. In 2007, the Agency for Healthcare Research and Quality (AHRQ) estimated the average cost of shingles and its complications to be $566 million a year while another study estimated the overall cost could be as high as $1.7 billion a year. The disease also takes a toll on the health and quality of life of those who have been afflicted. Postherpetic neuralgia (PHN) is the most common complication; however, other lingering and potentially severe complications and pain can impact an individual for months.

AVAC urges CMS to maintain the herpes zoster vaccination process measure in the final rule and we hope that other value-based purchasing and quality reporting programs will consider this measure in the future, particularly since the absence of zoster vaccination measures has been identified by the National Quality Forum as a significant gap in performance measurement and the development of a measure has recently been identified as a priority.

Thank you for the opportunity to offer our perspective on this proposed rule. Please contact the AVAC Coalition Manager at (202) 540-1070 or info@adultvaccinesnow.org if you wish to discuss our comments or adult immunization issues.

Sincerely,

American Association of Occupational Health Nurses

American College of Preventive Medicine

Asian & Pacific Islander American Health Forum

BIO

Gerontological Society of America

Immunization Action Coalition

Infectious Diseases Society of America

National Association of County and City Health Officials

National Foundation for Infectious Diseases

Pfizer

Takeda

Trust for America’s Health

AVAC Urges CMS to Include Adult Immunization Quality Measures in Outpatient Prospective Payment System (OPPS) Proposed Rule

AVAC submitted a response to the 2016 CMS Hospital Outpatient Prospective Payment Proposed Rule (OPPS). AVAC expressed support for maintaining Influenza Vaccination Coverage among Healthcare Personnel (NQF #0431) in the Outpatient Quality Reporting (OQR) Program for the CY 2018 payment determination and subsequent years. AVAC also encouraged CMS to consider including pneumococcal immunization measures in the OQR program and urged them to consider including additional adult immunization quality measures into the OQR Program in future rulemaking

Letters to Administration

Quality Measures

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As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the fiscal year 2016 CMS Hospital Outpatient Prospective Payment Proposed Rule (OPPS).

AVAC consists of more than 35 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 healthcare 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.

In this vein, we would like to express our support for maintaining Influenza Vaccination Coverage among Healthcare Personnel (NQF #0431) in the Outpatient Quality Reporting (OQR) Program for the CY 2018 payment determination and subsequent years. Leading medical and health professional associations support influenza vaccination policies for healthcare professionals to help protect patients.1 Healthcare personnel are the first line of defense when it comes to preventing illness and preserving health. Quality measurement reflecting this priority is essential to promoting and advancing prevention in the outpatient healthcare setting and should remain a priority within the Hospital OQR Program.

AVAC also encourages CMS to consider including pneumococcal immunization measures in the OQR program. The health and economic burden of pneumococcal disease, particularly among elderly and high risk adult populations, is significant. Yet, pneumococcal vaccination rates remain inadequate, with only 62 percent of adult over the age of 64 and 20 percent of high risk adults being vaccinated.

Moreover, we urge CMS to consider including additional adult immunization quality measures into the OQR Program in future rulemaking. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine preventable diseases while adult coverage remains well below Healthy People 2020 targets for most commonly recommended vaccines (influenza, pneumococcal, tetanus, HepB, herpes zoster, HPV). Millions more adults suffer from vaccine-preventable diseases, causing them to miss work and leaving them unable to care for those who depend on them. Prioritizing additional quality measures around immunizations in the Hospital OQR Program would help identify measure gaps, improve upon immunization rates and create greater health outcomes across adult populations.

The FY16 proposed rule also notes intent to develop a comprehensive set of quality measures to be available for widespread use for making informed decisions and quality improvement in the ASC setting. CMS should consider including additional quality measures covering vaccine preventable disease as part of CMS’ future measure selection and development for the ASCQR. CMS states that future quality measures could be aligned with the National Quality Strategy (NQS), the CMS Strategic Plan, and other CMS quality reporting and value-based purchasing programs. AVAC fully supports the alignment of reporting mechanisms and believes doing so will strengthen and enhance the development and implementation of adult immunization quality measures. Immunization is “effective prevention” in reducing rates of morbidity and mortality from a growing number of preventable conditions and has been demonstrated to improve overall health in a cost efficient manner.

AVAC Expresses Strong Concerns Over Changes in 2016 Medicare Program Hospital Inpatient Prospective Payment System Proposed Rule

AVAC was deeply concerned that the 2016 Medicare Program Hospital Inpatient Prospective Payment System proposed rule seeks to remove the IMM-1 (Pneumococcal Immunization -NQF #1653) from the Hospital IQR Program beginning in FY2016 for the FY 2018 payment determination and in subsequent years. Immunization quality measures are a crucial tool for health care quality improvement and have demonstrated effectiveness in increasing immunization rates. The significant health and economic burden of pneumonia on elderly and medically vulnerable populations and sub-optimal pneumococcal immunization rates remain public health imperatives that require continued leadership from CMS.

Letters to Administration

Quality Measures

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June 16, 2015

Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1632-P
P.O. Box 8013
Baltimore, MD 21244-1850

RE: CMS-1632-P Medicare Program: Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System Policy Changes and Fiscal Year 2016 Rates

To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on CMS-1632-P FY 2016 Medicare Program Hospital Inpatient Prospective Payment System proposed rule.

AVAC consists of organizational leaders in health and public health that are committed to tackling the range of barriers to adult immunization, to raise awareness of and to engage 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, and protecting lives against a variety of debilitating and potentially deadly conditions, as well as by saving costs to the healthcare system and to society as a whole.

AVAC priorities and objectives are driven by a consensus process with the goal of improving access and utilization of adult immunizations. 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. Required measures through the Medicare hospital inpatient program play a critical role in promoting improved care quality.

That is why we are deeply concerned that the proposed rule seeks to remove the IMM-1 (Pneumococcal Immunization -NQF #1653) from the Hospital IQR Program beginning in FY2016 for the FY 2018 payment determination and in subsequent years. The 2014 National Healthcare Quality and Disparities Report by the Agency for Health Care Research and Quality (AHRQ) found that publicly-reported CMS measures were much more likely than measures reported by other sources to stimulate high levels of performance and specifically note hospital patients age 65+ who received pneumococcal screening or vaccination as an area of success.¹

Furthermore, removing IMM-1 is a step in the wrong direction for health care quality improvement, particularly when CMS is seeking to expand care improvement and readmissions measurement for patients with a pneumonia diagnosis. It is also in contrast to CMS’ Quality Improvement Network Quality Improvement Organization (QIN-QIO) 11th Scope of Work (SOW) that includes strategies aimed at improving reporting of all adult immunizations and increasing immunization rates among the Medicare population.

Pneumonia is responsible for over a million hospitalizations and 50,000 deaths each year in the United States. Vaccines are an effective intervention against the high cost of medical care and rates of preventable death associated with this disease, particularly among medically vulnerable populations and the elderly. That is why the Advisory Committee for Immunization Practices (ACIP) 2014 recommendations call for adults aged 65 years or older and individuals with underlying immunocompromising health conditions between 19 and 64 years of age to receive PCV13 and PPSV23. ACIP also recommends PPSV23 for adults 19 through 64 years of age with underlying chronic health conditions like diabetes, heart disease, liver disease or lung disease (including people who smoke or have asthma).

We strongly encourage CMS to modify its approach and preserve pneumococcal immunization measurement in the Hospital IQR program in the final rule. We recognize CMS concern that the current language of IMM-1 is insufficient to capture full immunization of a person over 65 years of age with BOTH ACIP-recommended pneumococcal vaccines. However, rather than rescinding the current IMM-1 measure, we instead urge CMS to work with immunization stakeholders to revise the current language to reflect the recommendations of the ACIP. We would note that the National Quality Forum (NQF) Health and Well-Being Standing Committee is in the process of updating its standards specifications for pneumococcal vaccinations so CMS can assess the IMM-1 measure against the revised standards specifications. The Joint Commission has transferred measure stewardship for IMM-1 to CMS so the changes necessary to bring the measure into compliance with ACIP- recommendations can be implemented.

We also believe that the process of removing the current IMM-1 measure and starting over with the development of a new measure will require more resources and time, with potential detrimental impact to public health. We thus again urge CMS to follow the process of updating the existing measure to better align to ACIP recommendations.

Immunization quality measures are a crucial tool for health care quality improvement and have demonstrated effectiveness in increasing immunization rates. The significant health and economic burden of pneumonia on elderly and medically vulnerable populations and sub-optimal pneumococcal immunization rates remain public health imperatives that require continued leadership from CMS.

Lastly, we would also like to express our support for the proposal to maintain IMM- 2, the Influenza Immunization Measure, as part of the Hospital IQR program for FY 2018 and subsequent years. We agree with CMS’ assessment that the benefits outweigh the disadvantages of retaining IMM-2. Moreover, this measure plays a critical role in the CMS Quality Strategy as well as the National Quality Strategy in terms of influenza immunization efforts.

We thank you for this opportunity to offer our perspective on this important public health issue. Please contact the AVAC Coalition Manager at (202) 540-1070 or lfoster@nvgllc.com if you wish to further discuss our comments or learn more about the work of AVAC.

Sincerely,

American Association of Occupational Health Nurses

American College of Preventive Medicine

Biotechnology Industry Organization

Immunization Action Coalition

Infectious Diseases Society of America

National Association of County and City Health Officials

National Foundation for Infectious Diseases

National Minority Quality Forum

Pfizer

Sanofi Pasteur

Takeda Vaccines

Trust for America’s Health

¹ AHRQ, “2014 National Healthcare Quality and Disparities Report p.
http://www.ahrq.gov/research/findings/nhqrdr/nhqdr14/2014nhqdr.pdf

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