AVAC Releases Statement Applauding CMS for Recommending that Part D Plans Offer Covered Vaccines at No or Low-Cost

AVAC applauded CMS for once again recommending that Part D plans offer covered vaccines to all beneficiaries at no or low-cost in the 2017 Medicare Advantage (MA) and Part D Payment Policies and Final Call Letter. No American should be denied access to life-saving vaccines because they lack the ability to pay.

The following is a statement from the Adult Vaccine Access Coalition (AVAC), regarding the adult vaccine provisions of the Centers for Medicare and Medicaid Services 2017 Medicare Advantage (MA) and Part D Payment Policies and Final Call Letter

“The Adult Vaccine Access Coalition (AVAC) applauds the Centers for Medicare and Medicaid Services (CMS) for once again recommending that Part D plans offer covered vaccines to all beneficiaries at no or low-cost. No American should be denied access to life-saving vaccines because they lack the ability to pay.

Adult immunization receives scant attention but has significant health and financial repercussions. 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—particularly among minority populations for whom immunizations rates are typically far lower than average. Vaccine preventable diseases also cost the United States billions of dollars each year in entirely avoidable healthcare expenditures, lost wages and other indirect economic costs.

As a diverse coalition of health care providers, vaccine manufacturers, pharmacies, and public health, patient, and consumer groups, AVAC is committed to improving Americans’ health by ensuring that recommended vaccines reach more people who need them. We strongly urge all Part D plans to follow CMS’s recommendations and make all covered vaccines available to all beneficiaries free of charge.”

AVAC Urges Congress to Prioritize Funding for Adult Immunization-related Activities at HHS

AVAC sent a letter to members of the House of Representatives and the Senate asking them to prioritize funding for adult immunization-related activities at the Department of Health and Human Services (HHS). Specifically, AVAC requested $650 million for the national immunization program, also known as the 317 program, at the CDC; $82 million in Public Health Service Evaluation Funds for the Office of the National Coordinator for Health IT (ONC); and $6.4 million for the National Vaccine Program Office (NVPO) at HHS.

Dear Senators/Representatives:

As you prepare the Fiscal Year (FY) 2017 Labor, Health and Human Services, Education, and Related Agencies Appropriations bill, we urge you to prioritize funding for adult immunization-related activities at the Department of Health and Human Services (HHS).

Every year, more than 50,000 adults die from vaccine-preventable diseases, and thousands more suffer serious health problems that cause them to miss work and leave them unable to care for those who depend on them. Despite Advisory Committee for Immunization Practices (ACIP) recommendations, vaccines have been consistently underutilized in the adult population and lag far behind the Healthy People 2020 goals for the most commonly recommended vaccines (influenza, pneumococcal, Adult Tetanus, Diphtheria, Pertussis (Tdap), shingles, Human Papillomavirus (HPV)). These disparities are even greater when you consider at-risk populations – including seniors, communities of color, limited English proficient persons, and people with chronic illness.

The Adult Vaccine Access Coalition (AVAC) works to raise awareness, improve access, and increase utilization of vaccines among adults. AVAC consists of 45 organizational leaders that include health care providers, vaccine makers, pharmacies, public health organizations, patient and consumer groups working to strengthen and enhance access to and utilization of adult immunizations.

AVAC asks that you consider the benefits of protecting adults against vaccine-preventable disease, the challenges and barriers currently impeding adult immunization, and, the need to catalyze action to strengthen the vaccine infrastructure and delivery systems across the country during the FY17 appropriations process. Specifically, we urge you to prioritize the following immunization related programs as part of your FY17 appropriations request:

  • Centers for Disease Control and Prevention (CDC) Section 317 Immunization Program. We ask that Congress provide $650 million for the national immunization program, also known as the 317 program, at the CDC. A robust immunization infrastructure is critical to support and protect the population against common preventable conditions as well as potential disease outbreaks or public health emergencies. The Section 317 program acts as the backbone of our nation’s public health infrastructure. This national, state and local network also provides a safety net to uninsured and poor adults, monitors the safety of vaccines, educates providers and performs community outreach, and conducts surveillance, laboratory testing, and epidemiology to respond to disease outbreaks. AVAC is particularly interested in 317 program investments in Immunization Information Systems (IIS) that improve data exchange security standards and enhance interfacing with electronic health records (EHRs). IIS’ can help inform providers and support clinical decision-making in terms of a patient’s immunization status as well as help determine recommended vaccines.
  • Office of the National Coordinator for Health IT. We ask that Congress support $82 million in Public Health Service Evaluation Funds for the Office of the National Coordinator for Health IT (ONC). Advancements in health IT (HIT) create opportunities for greater access to and utilization of immunizations among adults. Technology has the power to inform providers about recommended vaccines for the adult population. The ONC is engaged in pilot studies aimed at tackling technological and logistical barriers that will foster a provider’s ability to receive and send a comprehensive record of a patient’s immunization status to determine which vaccines are needed. ONC is also leading important work that will enable patients, family members and other caregivers to directly access immunization records through a web-based portal. These pilot studies hold great promise and should be expanded to test other innovative models that will help to improve the exchange of timely and complete immunization record information.
  • National Vaccine Program Office. We urge Congress to provide level funding of $6.4 million for the National Vaccine Program Office (NVPO) at HHS. These dollars will help ensure robust implementation of the National Adult Immunization Plan (NAIP). This comprehensive plan lays out overarching goals along with a series of tangible objectives aimed at raising adult immunization rates in line with Healthy People 2020 targets. The NAIP also contains specific milestones intended to monitor progress on improving adult immunization.

The future for adult immunization is bright but adequate funding will be essential to achieving success in addressing the current barriers and challenges to improved access and higher coverage rates for this population. We appreciate your consideration of funding for adult immunizations at CDC, ONC, and NVPO. We look forward to working with your office as the FY17 appropriations process moves forward. For further information, please contact the AVAC mangers at 202-540-1070 or info@adultvaccinesnow.org.

Sincerely,

Alliance for Aging Research
American College of Preventive Medicine (ACPM)
Asian & Pacific Islander American Health Forum (APIAHF)
Biotechnology Innovation Organization (BIO)
GSK
Immunization Action Coalition
Infectious Diseases Society of America
March of Dimes
National Association of City and County Health Officials (NACCHO)
National Viral Hepatitis Roundtable (NVHR)
Novavax
Pfizer
Sanofi Pasteur
Takeda
The Gerontological Society of America
Trust for America’s Health

AVAC Responds to CMS 2017 Medicare Advantage and Part D Advance Notice and Draft Call Letter

AVAC shared comments on CMS’s 2017 Medicare Advantage and Part D Advance Notice and Draft Call Letter. AVAC asked CMS to reinforce its call for Part D plans to include vaccines in the $0 cost sharing tier in the final letter and work to find the right balance between plans’ fiduciary responsibilities and beneficiary access to essential preventive health services.

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) 2017 Medicare Advantage and Part D Advance Notice and Draft Call Letter.

AVAC consists of over 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.

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 efforts to address specific challenges vulnerable populations face in order to close gaps in immunization coverage and improve adult immunization rates overall.

Immunizations are a cornerstone of our nation’s disease prevention efforts and have a demonstrated track record of success as a cost-effective means of reducing disease burden and saving lives among pediatric populations. Yet, 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, hepatitis B, 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. At risk populations, including the frail elderly, also lag behind Healthy People 2020 adult immunization goals, yet are particularly vulnerable to the adverse health consequences of vaccine preventable illness.

Immunization coverage for Medicare beneficiaries is segmented between Medicare Part B, which covers vaccinations against influenza, pneumococcal and hepatitis B for at-risk patients and Medicare Part D, which covers all other commercially available vaccines. While beneficiaries receive Part B-covered vaccines with no cost sharing, Part D vaccines are typically subject to cost sharing requirements. Significant beneficiary cost sharing under Medicare Part D create barriers to access and may hinder public health and provider efforts to improve rates among these subgroups.

Immunization meets the three aims of the CMS Quality Strategy — Better Care; Smarter Spending; and Healthier People and should be strengthened and enhanced in order to provide greater access to and utilization of adult immunization services amongst the Medicare population. In this vein, AVAC would like to offer comments with regard to the following sections of the 2017 draft call letter that we believe would strengthen adult immunization amongst Medicare beneficiaries.

Changes to Star Ratings Measures for MA Plans (page 146)

The draft call letter indicates that the National Committee for Quality Assurance (NCQA) is presently considering a modification to the “Pneumococcal Vaccination Status for Older Adults” measure collected by the Medicare Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey. This patient-based survey measure assesses the percentage of Medicare members 65 years of age and older who have ever received a pneumococcal vaccination. AVAC was pleased to submit comments in support of the interim change to better account for the 2014 Advisory Committee on Immunization Practices (ACIP) recommendation that all adults 65 years of age and older receive sequential administration of both PCV13 and PPSV23. While the proposed question does not specify PCV13 and PPSV23, the order in which patients should be vaccinated, or the amount of time between which the two immunizations should initially occur, we believe this interim step will improve alignment with current guidelines and help provide better information in terms of whether or not adults age 65 and older are being accordance with ACIP recommendations for pneumococcal vaccination.

Last year, the Health and Well-Being Committee for the National Quality Forum (NQF) 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 continue to work with NCQA and other relevant quality measure stakeholders to update, refine and streamline pneumococcal vaccination-related quality measures.

Maintains $0 cost sharing tier recommendation (page 189)

The 2017 draft call letter notes the continued lack of meaningful progress toward Healthy People 2020 targets. Despite ACIP’s evidence-based clinical guidelines on the appropriate ages and dosing of recommended vaccines for adult immunization, rates still remain extremely low. According to 2014, CDC National Health Information Survey (NHIS) data, disparities in adult immunization coverage rates are even more striking among communities of color, limited English proficient persons, and people with chronic illness.

There is a growing body of scientific evidence that indicates financial barriers to Part D vaccines impede beneficiary access to immunization services. For instance, a 2011 Government Accountability Office (GAO) report on factors affecting access to Medicare Part D vaccinations found that many of the almost 22 million Medicare beneficiaries age 65 and older who were enrolled in Medicare Part D in 2009 did not receive the routinely recommended vaccinations covered by Part D.3 The GAO report survey of physicians found that physicians often cited cost sharing affordability for beneficiaries as a barrier to access to recommended vaccines. Last year, an Alliance for Aging Research report on vaccination rates among older adults found that cost sharing for vaccines under Part D varies depending on a beneficiary’s prescription drug plan or Medicare Advantage plan formulary offerings.4 Recently, a report by Avalere Health found between 47 and 72 percent of the 24 million Medicare beneficiaries with Part D coverage had some level of cost sharing for vaccines, ranging from $35 to $70 in 2015. 5AVAC strongly supports CMS call letter language encouraging Part D sponsors to consider offering $0 or low cost sharing for vaccines.

We encourage CMS to maintain this language in the final letter and further emphasize the importance of this benefit and work more aggressively to address the barrier of cost sharing to beneficiary access to this essential preventive health service. Specifically, AVAC urges CMS to consider offering incentives, such as allowing to Part D plan sponsors count spending on beneficiary education campaigns and other efforts to promote access to ACIP recommended vaccines toward medical loss ratio (MLR) totals, when those plans transition vaccines from higher cost sharing tiers to the $0 cost sharing tier option.

The variable cost sharing requirements currently imposed on the majority of Part D vaccines discourages immunization among elderly, disabled and chronically ill populations who account for disproportionate percentage of the morbidity and mortality from vaccine preventable conditions. Removing this financial barrier would have a significant impact on beneficiary access and utilization of Part D vaccines. As new vaccines for a growing variety of infectious and devastating conditions enter the market, reducing this barrier will be even more important to improving uptake that will save lives and money.

Improvement Measures for MA and Part D plans (page 226)

The draft call letter indicates that the annual influenza vaccine is being considered for inclusion among process improvement measures for which Medicare Advantage (MA) plans will be judged.

The 2015 Institute of Medicine (IOM) report “Vital Signs: Core Metrics for Health and Health Care Progress” highlights the value of preventive services such as immunization, noting that, “more than 75 percent of U.S. health care expenditures is related to the treatment of preventable conditions, only an estimated 3 percent is devoted to prevention and public health improvement activities.”6

Immunization is “effective prevention” to reduce rates of morbidity and mortality from a growing number of preventable conditions and has been demonstrated to improve overall health.

According to the Centers for Disease Control and Prevention (CDC), influenza alone cost $10.4 billion in direct health care costs during the 2013-14 flu season.7 However, CDC estimates that each influenza vaccination saves $80 per year per person vaccinated, averting 90,000 hospitalizations. AVAC supports the inclusion of annual influenza immunization among MA process improvement measures as a means to ensure this critical disease prevention tool is being utilized.

Thank you for the opportunity to offer our perspective on the 2017 Medicare Advantage and Part D Advance Notice and Draft Call Letter. We hope CMS will reinforce its call for Part D plans to include vaccines in the $0 cost sharing tier in the final letter and work to find the right balance between plans’ fiduciary responsibilities and beneficiary access to essential preventive health services. Please contact an AVAC manager at (202) 540-1070 or info@adultvaccinenow.org if you wish to discuss our comments or adult immunization.

Sincerely,

Alliance for Aging Research
American College of Preventive Medicine (ACPM)
Asian & Pacific Islander American Health Forum (APIAHF)
Biotechnology Innovation Organization (BIO)
Immunization Action Coalition
National Association of City and County Health Officials (NACCHO)
Sanofi Pasteur
Takeda Vaccines
The Gerontological Society of America

AVAC Responds to the Centers for Medicare and Medicaid Services (CMS) Quality Measure Development Plan (MDP)

The Measure Development Plan (MDP) outlined the nine MACRA requirements of the MDP and sets for CMS’ proposed approach to each requirement. AVAC offered comments on each of the following MACRA requirements.

March 1, 2016

RE: CMS Quality Measurement Development Plan: Supporting the Transition to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs)

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) Quality Measure Development Plan (MDP).

AVAC consists of 46 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 federal benchmarks and quality measures to encourage more comprehensive tracking and reporting of immunization status that will result in increased adult immunization rates.

Measure Development Plan Purpose

AVAC supports the range of CMS work currently being undertaken to streamline process and outcome measures and align these measures across providers and payment systems. This extensive undertaking requires a coordinated effort that includes public and private payers, health care providers as well as patients and caregivers. AVAC appreciates that CMS is committed to the goals of addressing known measurement and performance gaps while also employing strategies to ensure that the burden of quality measure reporting on providers is minimized.

Immunizations are a cornerstone of our nation’s disease prevention efforts and have a demonstrated track record of success as a cost-effective means of reducing disease burden and saving lives among pediatric populations. Yet, 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, hepatitis B, 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. Immunization meets the three aims of the CMS Quality Strategy — Better Care; Smarter Spending; and Healthier People. We urge CMS to consider the development of additional adult immunization quality measures that align with the age and health status recommendations of the Advisory Committee for Immunization Practices (ACIP). Prioritizing additional quality measures around immunizations through MACRA funding as part of the MDP would help to address identified measure gaps, improve upon immunization rates and create greater health outcomes across adult populations.

CMS Strategic Vision

AVAC supports consistent and comprehensive quality measure sets for widespread use to inform clinical decision making at the point of care and improve quality in the provider setting. CMS has made the alignment of quality measures with the National Quality Strategy (NQS), the CMS Strategic Plan, and other CMS quality reporting and value-based purchasing programs a priority. 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. Over the past year, AVAC has submitted numerous regulatory comment letters urging greater standardization of immunization measures across CMS programs, including the physician quality reporting system (PQRS), the meaningful use and electronic health records (MU/EHR) inventive programs and new merit incentive payment systems (MIPS). AVAC is also in agreement with the general and technical principles set forth in the draft MDP.

The draft MDP references a number of important baseline quality measures, as well as relevant publications and reports aimed at informing the quality measure framework and development process. AVAC would urge you to consider the August 2014 NQF report “Priority Setting for Healthcare Performance Measurement: Addressing Performance Measure Gaps for Adult Immunizations”, which provides a comprehensive overview of the current state of adult immunization measures and gap analysis on areas where more work is needed. In general, the report highlights the lack of measures for certain vaccine-preventable conditions that disproportionately affect adults (e.g. herpes zoster), while other diseases that significantly impact adults, particularly the elderly and those with chronic conditions (e.g. influenza and pneumonia) have multiple, overlapping measures across CMS programs. We agree with NQF’s finding that reducing the burden and improving the value of measurement and measures should be harmonized and consolidated and “at a minimum, all measures should be up to date with current ACIP/CDC recommendations.”1 We also support their proposed short-term and long-term prioritization of measurement needs. This includes a process for quality measures for newly approved ACIP recommended vaccines.

Operational Requirements of the Quality Measure Development Plan

The MDP outlines the nine MACRA requirements of the MDP and sets for CMS’ proposed approach to each requirement. AVAC would like to offer the comments with regard to each of the following MACRA requirements.

1) Multi-Payer Applicability of Measures – CMS outlines the variety of initiatives designed to create aligned core measure sets across both public and private payers. These efforts include the Measure Applications Partnership (MAP), the Core Quality Measures Collaborative and the Health Care Payment Learning and Action Network (HCPLAN).

a. Measure Applications Partnership – AVAC was pleased to submit comments to the NQF MAP in December 2015 in response to the 2015 measures under consideration. Those comments supported process measures for immunization against hepatitis A and hepatitis B as well as influenza for Medicare beneficiaries with liver diseases and urged NQF to continue building and improving upon immunization measures currently found in PQRS as work to develop core measures for MIPS continues.

b. Core Quality Measures Collaborative – AVAC appreciates the work of the Collaborative in producing 7 core measure sets that will be expanded upon and finalized through a formal rulemaking process. We were disappointed immunizations were not included in the initial round of measure sets given they represent one of the most cost effective means of primary prevention, especially in adults with chronic conditions. We look forward to working with the Collaborative to ensure that immunization is an integral part of measure sets moving forward.

c. Health Care Payment Learning and Action Network (HCPLAN)— AVAC is pleased to be a member of HCPLAN and appreciates the working group designed to tackle specific issues and challenges around the development of new payment models.

2) Coordination and Sharing Across Measure Developers – AVAC strongly supports CMS efforts to coordinate and share knowledge and best practices among federal and non-federal quality measure development partners. This approach will ensure strong measures that can be adopted across payment settings and providers. Greater attention and focus on adult immunization measures will strengthen prevention efforts while reducing the burden on providers and providing a more meaningful and effective core set of measures in this area. Consistent application of immunization measures by providers and health care settings will enable seamless tracking of a patient’s immunization status and provide an accurate and complete record that will help inform and improve clinical decision-making and health outcomes, reduce missed opportunities to immunize as well as protect against over immunizing.

3) Clinical Practice Guidelines – MACRA requirements call for CMS to take into account clinical best practices and guidelines in the development of quality measures. AVAC urges CMS to consider the recommendations of the Advisory Committee on Immunization Practices (ACIP) as a resource on adult immunization. ACIP is a formal advisory group of medical and public health experts who develop evidence-based recommendations on the appropriate use of vaccines, including at what ages a vaccine should be given, number of doses needed and intervals, as well as potential contraindications. These recommendations represent the gold standard in immunization clinical practice.

4) Evidence Base for Non-Endorsed Measures – The MDP indicates that CMS plans to “use the rating criteria established by NQF to evaluate the quality, quantity and consistency of the evidence for the development of quality measures included in the plan.”2 AVAC urges CMS to conduct an extensive gap analysis to identify ACIP-recommended adult immunizations for which there is no corresponding quality measure and work with measure developers to address these gaps.

5) Quality Measure Domains and Priorities – The MDP outlines a series of quality domains required under MACRA. AVAC urges CMS to give serious consideration to adult immunization quality measures under the population health and prevention quality domain. The IOM report “Vital Signs: Core Metrics for Health and Health Care Progress” highlights the value of preventive services such as immunization, noting that, “more than 75 percent of U.S. health care expenditures is related to the treatment of preventable conditions, only an estimated 3 percent is devoted to prevention and public health improvement activities.”3 Immunization is “effective prevention” to reduce rates of morbidity and mortality from a growing number of preventable conditions and has been demonstrated to improve overall health.

6) Gap Analysis – The MDP indicates that CMS will prioritize the development of measures in areas where gaps in provider performance and variation in care present opportunities for meaningful improvement. We strongly urge CMS to review the findings and adopt the recommendations of the August 2014 NQF report “Priority Setting for Healthcare Performance Measurement: Addressing Performance Measure Gaps for Adult Immunizations”.

7) Applicability of Measures Across Healthcare Settings – AVAC supports CMS efforts to streamline and standardize quality measures for use across health care settings and providers. We urge CMS to prioritize adult immunization measures through the MDP and related quality measure processes by conducting a comprehensive review of existing adult measures, streamlining redundant and outdated measures currently being used, while also working to address identified gaps in adult immunization measures by rapidly advancing new measures covering a broader array of ACIP recommended vaccines for adults. We believe such an effort would provide a solid foundation of strong core immunization measures as we transition to new payment models that will rely heavily on accurate and effective quality performance measures.

8) Clinical Practice Improvement Activities – The National Immunization Survey tracks progress in immunization rates across a range of preventable conditions, looking at specific age groups and populations. Our nation is woefully deficient in advancing adult immunization coverage, particularly among the elderly and underserved communities of color. AVAC encourages CMS to include adult immunization measures among the clinical practice improvement activities.

9) Consideration for Electronic Specifications – AVAC supports CMS efforts to leverage and integrate broader access to a range of data originating from patient registries, clinical data repositories and common data elements. AVAC was also pleased to offer comments in response to the proposed electronic clinical quality measures (eCQMs) for influenza immunization for use by providers in CMS quality reporting programs and hopes CMS will work to put forth additional eCQMs pertaining to adult immunization.

Thank you for the opportunity to offer our perspective on the MDP. Adult immunization measures have been integral to existing CMS quality measures systems and should be a core element in future quality measurement frameworks. Please contact an AVAC manager at (202) 540-1070 or info@adultvaccinesnow.org if you wish to discuss our comments or adult immunization.

American College of Preventive Medicine
Asian & Pacific Islander American Health Forum (APIAHF)
Biotechnology Innovation Organization (BIO)
Immunization Action Coalition
National Viral Hepatitis Roundtable (NVHR)
Novavax
Pfizer
Sanofi Pasteur
Takeda
The Gerontological Society of America

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.

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.

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 policies that will improve access to the full complement of vaccines recommended for adults by the Advisory Committee on Immunization Practices (ACIP).

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).

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.

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.

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 policies that will improve access to the full complement of vaccines recommended for adults by the Advisory Committee on Immunization Practices (ACIP).

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.