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

AVAC Supports CMS Changes to the Electronic Health Record Incentive Program

AVAC appreciated the opportunity to comment on CMS-3311-P Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Modifications to Meaningful Use in 2015 Through 2017. AVAC applauded CMS for including bidirectional information exchange between provider EHR systems and Immunization Information Systems (IIS) because the ability to report immunization events as well as receive information regarding the immunization status of a patient is a remarkable step forward in improving the quality of patient care and as well as avoiding preventable illness. AVAC also encouraged CMS to work closely with federal, state and local public and private sector organizations to ensure that the timetable put forth in this proposed rule compliments efforts through Stage 3 Meaningful Use as well as ONC’s HIT Certification program criteria and modifications.

Letters to Administration

Vaccine Infrastructure

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June 15, 2015

Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services Attn: CMS-3311-P
P.O. Box 8013
Baltimore, MD 21244-8013

RE: CMS-3311-P Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Modifications to Meaningful Use in 2015 Through 2017

To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on CMS-3311-P Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Modifications to Meaningful Use in 2015 Through 2017.

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 in 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.

We applaud CMS for including bidirectional information exchange between provider EHR systems and IIS’. The ability to report immunization events as well as receive information regarding the immunization status of a patient and providing cues as to appropriate immunizations for that individual based on their age and health status is a remarkable step forward in improving the quality of patient care and as well as avoiding preventable illness.

We encourage you to work closely with federal, state and local public and private sector organizations to ensure that the timetable put forth in this proposed rule compliments efforts through Stage 3 Meaningful Use as well as ONC’s HIT Certification program criteria and modifications. Bidirectional data exchange and query capability for Medicare and Medicaid providers through EHR systems is extremely important to overall efforts to improve immunization rates for the elderly and at risk populations. This work should closely align with complimentary efforts within the broader health care system in order to minimize the burden of compliance with these standards for providers and state immunization information systems alike.

Thank you for this opportunity to offer our perspective. 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

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

National Viral Hepatitis Roundtable

Pfizer

Sanofi Pasteur

Takeda Vaccines

Trust for America’s Health

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AVAC Emphasizes Important of Immunization Information Systems as CMS Considers the Stage 3 Meaningful Use Proposed Rule

A top priority for AVAC is encouraging greater utilization of health information technology to support clinical decision making and to improve reporting of adult immunization data to state immunization information systems (IIS). AVAC sent comments to CMS on the Stage 3 Meaningful Use proposed rule expressing concerns that the proposed rule no longer includes immunization registry reporting as a core objective for health care organizations and that the new query function requirement will not be successful if State and territorial jurisdictional IIS’ do not have adequate resources to manage the increased volume and onboarding efforts required to meet timelines and align with current and anticipated standards. AVAC also expressed support for replacing the ongoing submission requirement with the active engagement requirement.

Letters to Administration

Vaccine Infrastructure

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May 29, 2015

Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
Baltimore, MD 21244-8013

RE: CMS-3310-P Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 3

To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on CMS-3310-P Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 3.

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 by 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 encouraging greater utilization of health information technology to support clinical decision making and to improve reporting of adult immunization data to state immunization information systems (IIS). Stage 1 and Stage 2 Meaningful Use has begun to align the immunization documentation, reporting and communication systems and the usefulness of the information to patient care, and we are encouraged by the agency’s work to further enhance the objective outlined under Measure I (Immunization Registry Reporting).

Query Function for Measure I: The proposed rule includes the addition of a query function for the immunization registry measure for Stage 3. AVAC believes encouraging bidirectional data exchange between provider EHRs (including medical, pharmacy and health system information systems) and state IIS’ is a significant step forward that will inform and enhance clinical decision support at the provider point of care. While funding for IIS falls outside the scope of this proposed rule, we believe it is important to be mindful that the new query function requirement will only be successful if State and territorial jurisdictional IIS’ have adequate resources to manage the increased volume and onboarding efforts required to ensure that all bidirectional interfaces meet Meaningful Use timelines and align with current and anticipated standards. In addition, support for ALL adult immunization provider engagement and timely enrollment is vital to achieving comprehensive and impactful immunization registries.

Measure I Core Provider Objective: We are also concerned that the proposed rule no longer includes immunization registry reporting as a core objective for health care organizations. Stage 1 and Stage 2 Meaningful Use included Measure I as a core objective which we believe has helped to dramatically improve reporting of immunization data. Maintaining Measure I as a priority in Stage 3 is critical to sustaining progress, particularly as new capability requirements are being added to this measure. Abandoning Measure I at this time jeopardizes the progress that has been made to improve IIS reporting. We encourage CMS to maintain Measure I as a core objective under Stage 3.

Replacing Ongoing Submission requirement with Active Engagement requirement: AVAC supports the transition from Ongoing Submission to Active Engagement requirement since it provides greater clarity to the various stages providers are required to go through to achieve successful electronic submission of data to the PHA or CDR. We also strongly support the proposal to create a centralized repository of national, state and local PHA and CDR readiness. We are encouraged by the work of the Office of the National Coordinator on a pilot project to overcome challenges in the cross jurisdictional exchange of immunization data and hope that work can be expanded to more parts of the country.

Bidirectional Data Exchange required to satisfy Objective 8 Measure I: AVAC supports and represents this advancement and believes that it will enhance the value of immunization registry data to clinicians. The ability to receive timely information regarding the immunization status of a patient as well as providing cues as to appropriate immunizations for that individual based on their age and health status is a remarkable step forward in improving the quality of patient care and as well as avoiding preventable conditions. However, it is critical that IIS’ are in a position to receive the information from clinicians as well as respond to inquiries of the registry in a format that complies with Meaningful Use standards and having minimum burden on the provider.

We thank you for this opportunity to offer our perspective on the Stage 3 Meaningful Use proposed rule. 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,

Asian & Pacific Islander American Health Forum
Biotechnology Industry Organization
Infectious Diseases Society of America
GSK
National Association of County and City Health Officials National Minority Quality Forum
Novavax
Scientific Technologies Corporation
Trust for America’s Health

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AVAC Commends ONC for Working to Improve Immunization Information Systems

AVAC commended the Office of the National Coordinator for Health Information Technology (ONC) on their work to lay out coding criteria for the reporting of immunizations and to provide updated standards to ensure timely and accurate reporting of detailed information around immunization events. AVAC also applauded ONC for including bidirectional information exchange between provider electronic health record systems and immunization informations systems.

Letters to Administration

Quality Measures Vaccine Infrastructure

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May 29, 2015

Dr. Karen DeSalvo
Office of the National Coordinator for Health Information Technology U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

RE: RIN 0991-AB93 2015 Edition Health Information Technology (Health IT) Certification Criteria, 2015 Edition Base Electronic Health Record (EHR) Definition, and ONC Health IT Certification Program Modifications

Dear Dr. DeSalvo,

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on 2015 Edition Health Information Technology (Health IT) Certification Criteria, 2015 Edition Base Electronic Health Record (EHR) Definition, and ONC Health IT Certification Program Modifications.

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 by 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.

We commend ONC on your work to lay out coding criteria for the reporting of immunizations, current as well as historical, and to provide updated standards to ensure timely and accurate reporting of detailed information around immunization events.

In moving forward, we encourage you to work closely with federal, state and local public and private sector organizations who share ONC’s goal of building standardized coding systems and certification criteria that will enhance the value of IIS to providers and the public health community while minimizing the additional burden of compliance with these standards.

Additionally, we applaud ONC for including bidirectional information exchange between provider EHR systems and IIS’. The ability to report immunization events as well as receive information regarding the immunization status of a patient and providing cues as to appropriate immunizations for that individual based on their age and health status is a remarkable step forward in improving the quality of patient care and as well as avoiding preventable illness.

Your effort to include more detailed information around race, ethnicity, and primary/preferred language in immunization data reporting is an important step to addressing health disparities and authentic consent. This information would be valuable in the identification of health disparities in minority communities and help inform efforts to address gaps in access to immunization services.

Overall, we believe that ONCs work to align health information technology standards through the certification process will go a long way towards ensuring that a strong and sustainable interoperability network around immunization data reporting can be achieved. AVAC stands ready to work with you to reach this goal.

Sincerely,

Asian & Pacific Islander American Health Forum

Biotechnology Industry Organization

GSK

Infectious Diseases Society of America

National Association of County and City Health Officials National Minority Quality Forum

Novavax

Scientific Technologies Corporation

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AVAC Commends Introduction of Resolution Recognizing the Importance of Vaccinations

AVAC sent a letter to Representatives Schiff, Dent, Marino, and Welch, thanking them for introducing H.Res. 117, Recognizing the importance of vaccinations and immunizations in the United States. AVAC fully supports the resolution and thanks these representatives and others who have cosponsored the resolution for their commitment to and support for routine immunization, which protects lives against a range of vaccine-preventable conditions.

Letters to Congress

Benefits of Immunization

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March 25, 2015

Dear Representatives Schiff, Dent, Marino, and Welch:

As participants in the Adult Vaccine Access Coalition (AVAC) we would like to take this opportunity to commend you and all of the cosponsors for your leadership in introducing H.Res. 117, Recognizing the importance of vaccinations and immunizations in the United States.

We share your view that the reduction and elimination of infectious diseases by national immunization programs are one of the greatest public health achievements in modern times. For the past 60 years, national efforts to provide expanded access to immunization against a growing variety of vaccine-preventable conditions have stayed serious and life-threatening illnesses and their complications and saved the lives of millions.

AVAC is comprised of leaders in health and public health who are committed to tackling the range of barriers to adult immunization, and 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 routine immunization in improving health, protecting lives, as well as saving healthcare costs.

The principal objective of AVAC is to educate and engage policymakers in working toward common legislative and regulatory solutions that will strengthen and enhance access and utilization of adult immunization across the health care system.

Thank you for commitment to and support for routine immunization, which protects lives against a range of vaccine-preventable conditions. We are pleased to offer our support for H.Res. 117 and stand ready to work with you toward common solutions that will strengthen and enhance access to and utilization of vaccines across the health care system, particularly among the adult population. Please contact the AVAC Coalition Manager, at (202) 540-1070 or lfoster@nvgllc.com if you would like more information about AVAC or wish to be in contact on our work.

Sincerely,

American Academy of Family Physicians

American Association of Occupational Health Nurses, Inc.

American College of Preventive Medicine

American Pharmacists Association

American Public Health Association

Asian & Pacific Islander American Health Forum

Association of Professionals in Infection Control and Epidemiology

Biotechnology Industry Organization

GSK

Hep B United

Hepatitis B Foundation

Immunization Action Coalition

March of Dimes

Merck

National Association of County and City Health Officials

National Foundation for Infectious Diseases

National Indian Health Board

National Viral Hepatitis Roundtable

Pfizer Inc.

Sanofi Pasteur

Scientific Technologies Corporation

Takeda Vaccines, Inc.

Trust for America’s Health

cc: cosponsors of H.Res. 117

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AVAC Offers Comments on HHS’s National Adult Immunization Plan (NAIP)

AVAC was pleased to offer comments on the HHS National Vaccine Program Office’s (NVPO) National Adult Immunization Plan (NAIP). AVAC supports the goals highlighted in the NAIP. Improving access to and utilization of vaccines by reducing technological, logistical, geographic, socio-economic, and financial barriers to the full complement of ACIP-recommended adult immunizations. In the letter, AVAC highlighted several goals and objectives from the NAIP that we encourage NVPA to prioritize.

Letters to Administration

Quality Measures Reducing Financial Barriers Supporting Providers Vaccine Infrastructure

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March 23, 2015

Rebecca Fish
Senior Policy Advisor
National Vaccine Program Office
Department of Health and Human Services
Washington, D.C. 20515

Re: Solicitation of Written Comments on the Draft National Adult Immunization Plan

Dear Ms. Fish:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate this opportunity to comment on the HHS National Vaccine Program Office’s (NVPO) National Adult Immunization Plan (NAIP).

AVAC consists of 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 by 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 enabling the range of stakeholders to have a voice and a stake in the effort to improve access and utilization of adult immunizations. The NAIP comes at a critical time. National immunization campaigns to protect the population against vaccine-preventable diseases have been one of our most significant public health achievements, particularly among children. Despite this success, challenges and barriers continue to hinder efforts to achieve widespread immunization coverage in adult populations and as a result, significant disparities persist.

Importantly, the plan focuses on four key areas that will have the greatest impact on adult immunization rates: 1) Strengthen the adult immunization infrastructure; 2) Improve access to adult vaccines; 3) Increase community demand for adult immunizations and 4) Foster innovation in adult vaccine development and vaccination-related technologies. Complimenting these four goals are a set of targeted indicators and strategies that will benchmark and guide progress toward the four objectives.

AVAC member organizations similarly support improving access to and utilization of vaccines by reducing technological, logistical, geographic, socio-economic, and financial barriers to the full complement of ACIP-recommended adult immunizations. As you work to finalize the NAIP, we encourage you to prioritize the objectives and goals set forth in the plan. AVAC intends to prioritize certain goals and objectives that we have highlighted below as areas of common interest.

GOAL 1:

The first goal of the NAIP places a strong emphasis on the increasing role and importance of health information technology (HIT) and the need for systems and health care providers to be able to share and exchange immunization recommendations and data in a timely and accurate manner. While this goal lays out several important objectives, AVAC members most strongly support the following:

Objective 1.1: Monitor and report trends in adult vaccine-preventable disease levels and vaccination coverage data for all ACIP-recommended vaccines. In cases where there are associated Healthy People 2020 goals, measure progress toward established targets. Surveillance data to more accurately evaluate coverage gaps and disparities, particularly among minority and vulnerable populations, are essential to improving the impact of adult immunization efforts and expanding coverage. AVAC coalition members are working on projects that seek to identify and enhance our understanding of coverage gaps and are developing pilot programs to test targeted solutions where these disparities currently exist.

Objective 1.4: Increase the use of electronic health records (EHR) and immunization information systems (IIS) to collect and track adult immunization data. The AVAC shares this view that advancements in HIT have the potential to vastly improve monitoring of vaccine preventable disease rates and vaccine coverage data in real time as well as to facilitate the exchange of data that can improve the quality of preventive care among targeted adult populations, and patient outcomes. We see utilization of HIT and greater interoperability between EHRs and IIS systems as integral for tracking adult vaccination status, which is the first step in identifying needs where efforts and resources should be prioritized.

We also support the goals behind Objective 1.5 (Evaluate and advance targeted quality improvement initiatives) and Objective 1.6 (Generate and disseminate evidence about the health and economic impact of adult immunization, including potential disease burden averted and cost-effectiveness with the use of current vaccines). The latter objective should be prioritized and advanced quickly since this research will lay the groundwork for many other aspects of the NAIP. Quality improvement initiatives called for in Objective 1.5 are also a critical element to ensuring meaningful progress toward NAIP goals and objectives. AVAC members look forward to working with you in the development, evaluation and dissemination of these measures and metrics.

GOAL 2:

The second goal of the NAIP to improve access to adult vaccines is also critically important and is a core tenet for AVAC. The four objectives specified within this goal each include aspects that we support overall.

In general, we agree with Objective 2.1 (Reduce financial barriers for individuals who receive routinely recommended vaccines for adults) and Objective 2.2 (Assess and improve understanding of providers’ financial barriers to delivering vaccinations, including stocking and administering vaccines) and look forward to working with you toward deepening our understanding and further refining some of the specific elements articulated under each of these objectives.

Tackling the financial barriers that prevent adults from receiving recommended immunizations and hinder the ability of providers to stock and supply vaccines is essential to the ultimate success of the NAIP. Removing financial barriers will also contribute toward advancing Objective 2.3 (Expand the adult immunization provider network) and Objective 2.4 (Ensure a reliable supply of vaccines and the ability to trace vaccine inventories, including during public health emergencies). Predictable and timely supply will encourage a broader network of providers and sites (including the workplace) to offer immunizations to adult populations.

The Patient Protection and Affordable Care Act included provisions intended to improve access to adult immunization, yet barriers remain. In addition, fragmented coverage of ACIP recommended vaccines across Medicare Parts B and D and disparities in Medicaid coverage of vaccines across states (and even across eligible populations within a state) present significant barriers to vaccine access and utilization. Taking action to address these coverage challenges would be a significant accomplishment and would greatly improve access to immunization services for adults.

AVAC intends to develop an advocacy plan to tackle financial barriers to adult immunization that will include a review of public and private coverage of adult immunizations and solicit input from the range of our members on the financial barriers they perceive to be greatest. We look forward to sharing our findings and plan with you and other federal and non-federal stakeholders who will be involved in this effort.

GOAL 3:

Increasing community demand for adult immunizations, the third goal of the NAIP, also highlights an important aspect where greater attention and concerted effort is desperately needed in terms of the adult population. Education and awareness of the importance of immunization should be closely linked with efforts to improve access. The second and third goals of the NAIP should be viewed and pursued in tandem.

We appreciate that Objective 3.1 (Educate and encourage individuals to be aware of and receive recommended adult immunizations) places an emphasis on communication activities that are strategic, evidence-based, culturally-appropriate and reflect the health literacy, language proficiency and functional and access needs of specific target populations.

Objective 3.2 (Educate and encourage health care professionals to recommend and/or deliver adult vaccines) will be most impactful if barriers to access have been effectively addressed. Additionally, efforts to advance Objective 3.3 (Educate and encourage other groups to promote the importance of adult immunization) will result in an expanded network of adult immunizers and broaden the number of sites offering immunization services to adult populations. Focus and regular outreach are essential to establishing vaccination as a routine part of preventive care and building confidence in vaccination as a societal norm. We especially encourage initiatives aimed at boosting adult immunization rates among minority, at-risk, and vulnerable populations.

GOAL 4:

Lastly, innovation in adult vaccine development and vaccination-related technologies, goal 4 of the NAIP is important to building a sustainable foundation that will spur the development of next-generation vaccines and improve the effectiveness of current vaccine products against a host of preventable infectious diseases. Although AVAC is not focused on vaccine development and innovation, we recognize it as an important cornerstone that deserves attention and collaboration between federal and non-federal stakeholders.

CONCLUSION:

We applaud the NVPO for putting forth a National Adult Immunization Plan that lays out targeted goals, standards, and indicators for measuring progress in achieving those objectives. A focused, concerted approach to adult immunization with clear benchmarks and expectations of success are absolutely essential if we are going to reach Healthy People 2020 utilization and coverage targets for this population.

Stakeholder partners will play an essential role in helping bring the NAIP to fruition. AVAC shares in the common goals of reducing barriers and improving access and is dedicated to education and advocacy that will have a meaningful, positive, and lasting impact on adult immunization rates. We stand ready to work with NVPO and other federal and nonfederal stakeholders toward common solutions that will strengthen and enhance access and utilization of adult immunization across the health care system.

Thank you again for this opportunity to offer our perspective on the vision, goals and objectives of the National Adult Immunization Plan. Please contact the AVAC Coalition Manager at (202) 540-1070 or lfoster@nvgllc.com if you would like more information about AVAC or our work.

Sincerely,

American Academy of Family Physicians

American Association of Occupational Health Nurses, Inc.

American College of Preventive Medicine

American Pharmacists Association

American Public Health Association

Asian & Pacific Islander American Health Forum

Biotechnology Industry Organization

GSK

Hep B United

Hepatitis B Foundation

Immunization Action Coalition

Merck

National Association of County and City Health Officials

National Foundation for Infectious Diseases

National Indian Health Board

National Viral Hepatitis Roundtable

Pfizer Inc.

Sanofi Pasteur

Scientific Technologies Corporation

Takeda Vaccines, Inc.

Trust for America’s Health

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