June 26, 2017
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1671-P
P.O. Box 8016
Baltimore, MD 21244-8016
RE: CMS–1671-P Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2018
To Whom It May Concern:
As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the Medicare Program: Inpatient Rehabilitation Facility (IRF) Prospective Payment System proposed rule.
AVAC consists of over 50 organizational leaders in health and public health that are committed to addressing the range of barriers to adult immunization and to raising awareness of the importance of adult immunization. AVAC works towards common legislative and regulatory solutions that will strengthen and enhance access to adult immunization across the health care system. Our 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 improved tracking and reporting of immunization status that will result in increased adult immunization rates. Immunizations are an effective intervention to keep people healthy and avoid serious illness, disability, and deaths, particularly among medically vulnerable populations and the elderly.
Quality measurement programs through Medicare play a critical role in encouraging adherence and utilization of immunizations.
IRF Quality Reporting Program (IRF QRP).
AVAC supports the proposal to maintain the Percent of Residents or Patients Who Were Assessed and Appropriately Given the Seasonal Influenza Vaccine (Short Stay) (NQF #0680) and Influenza Vaccination Coverage among Healthcare Personnel (NQF #0431) among the 18 currently adopted quality measures in the IRF QRP outlined in Table 7. Influenza immunization measures help increase access and utilization of this important vaccine by patients and health care providers alike.
The Advisory Committee on Immunization Practices (ACIP) recommends an annual influenza vaccination for all people age 6 months or older. Each year, influenza causes approximately 200,000 hospitalizations and an average of 36,000 deaths in the United States each year. According to a study in the Journal of Primary Prevention, this vaccine-preventable disease costs the United States about $8.3 billion annually to treat among US adults 65 and over. Preventing transmission of influenza and other infectious agents within post-acute care settings requires a multi-faceted approach since the spread of influenza can occur among patients, Health Care Professionals (HCP), and visitors.
In addition, data transparency of reported measures is an important tool for patients and families seeking to evaluate post-acute care settings and an essential component in the identification and management of influenza outbreaks. Tracking vaccine status among health care workers has the ability to increase vaccination rates and reduce absenteeism among healthcare personnel.1 We support public reporting IRF QRP data on a CMS website, such as IRF Compare and support maintaining the two above measures in this campaign.
Other Measures to Consider for Future IRF QRP Inclusion.
AVAC believes the IRF QRP should include a focused, concerted approach to adult immunizations as a means of improving the overall health of patients in post-acute care facilities. We encourage CMS to consider prioritizing a broader set of ACIP recommended immunization measures for consideration for future inclusion in the IRF QRP. In particular, the current lack of pneumococcal quality measures in the IRF QRP is a missed opportunity to improve health and reduce unnecessary federal expenditures on treatment and hospitalizations as a result of this vaccine preventable disease.
Pneumonia is responsible for over a million hospitalizations and 50,000 deaths each year in the United States. That is why the 2014 Advisory Committee for Immunization Practices (ACIP) recommendations call for adults aged 65 years or older and individuals with underlying immunocompromising health conditions between 19 and 64 years of age to receive both PCV13 and PPSV23. ACIP also recommends PPSV23 for adults 19 through 64 years of age with underlying chronic health conditions like diabetes, heart disease, liver disease or lung disease (including people who smoke or have asthma).
Immunization has demonstrated “effective prevention” in reducing rates of morbidity and mortality from a growing number of preventable conditions and has been proven to improve overall health in a cost-efficient manner. Reducing the number of missed immunization opportunities is imperative to improving health and reducing the burden of vaccine preventable illness among the skilled nursing population.
Thank you for this opportunity to offer our perspective on this proposed rule being considered. Please contact the AVAC Coalition Manager at (202) 540- 1070 or info@adultvaccinesnow.org if you wish to further discuss our comments. To learn more about the work of AVAC visit www.adultvaccinesnow.org.
Sincerely,
Alliance for Aging Research
Asian & Pacific Islander American Health Forum
Immunization Action Coalition
National Association of County and City Health Officials
National Foundation for Infectious Diseases
Sanofi
Takeda Vaccines, Inc.
The Gerontological Society of America
1 https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6436a1.htm