As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the National Committee for Quality Assurance (NCQA) Proposed New Measure for HEDIS®1 2018: Pneumococcal Vaccination Status for Older Adults (PVS) included in its update to guidelines and measures using electronic clinical data systems (ECDS). We are pleased to offer our support for this measure.

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 more comprehensive tracking and reporting of immunization status that will result in increased adult immunization rates.

We greatly appreciate the work NCQA and others over the past year to study and test parameters that would ensure the collection of accurate and refined quality data that reflects the 2014 ACIP recommendation that adults age 65 and older receive a series of two pneumococcal vaccines: 13-valent pneumococcal conjugate vaccine (PCV13) and 23-valent pneumococcal polysaccharide vaccine (PPSV23). Presently, pneumococcal vaccination information is collected through the Consumer Assessment of Healthcare Providers and Systems (CAHPS®), which has limited capability to accurately collect or reflect the sequencing or other nuances of the updated ACIP- recommendation.

AVAC strongly support the inclusion of the following measure in the 2018 NCQA HEDIS measure set: Pneumococcal Vaccination Status for Older Adults. “The percentage of members 65 years of age and older who have ever received the recommended series of pneumococcal vaccines: 13-valent pneumococcal conjugate vaccine (PCV13) and 23-valent pneumococcal polysaccharide vaccine (PPSV23).”

The new measure aligns with the ACIP-recommendations in terms of vaccine sequencing and timing, allows for appropriate exclusions for individuals for whom vaccination may be contraindicated and encourages the use of electronic clinical data systems (claims, registries, EHRs) that are accessible to health care providers at the source of care as the means to collect measure data. AVAC would urge NCQA to provide for a period of transition between the CAHPS pneumococcal measure and the new ECDS-based measure. Collecting pneumococcal vaccination data through both methods for a period of time would enable NCQA to assess measure accuracy and help to identify potential gaps in data collection across these two sources.

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. Immunizations help save lives by protecting the health and wellbeing of individuals and families in communities nationwide.

Vaccines have dramatically reduced the spread of many crippling and potentially life-threatening diseases such as diphtheria, tetanus, measles, mumps, and rubella. Vaccines also prevent the spread of common infectious and potentially fatal diseases such as chickenpox, influenza, hepatitis A, hepatitis B, meningococcal disease, pneumococcal disease, and whooping cough (pertussis). Vaccines not only help protect the immunized person but also those around them who may not be able to be immunized because they are too young to be vaccinated themselves or suffer from a health condition that prevents them from being immunized.

Despite the demonstrated benefits of vaccination, every year, more than 50,000 adults die from vaccine-preventable diseases while adult coverage lags behind Healthy People 2020 targets for most commonly recommended vaccines: influenza, pneumococcal, tetanus, hepatitis B, herpes zoster, and HPV. Millions more adults suffer from vaccine-preventable diseases, causing them to miss work and leaving some unable to care for those who depend on them.

We are grateful to NCQA for taking action in light of the significant toll pneumonia takes in terms of lives and health care costs, particularly among our elderly population. We appreciate NCQA’s continued work to positively impact pneumococcal immunization coverage rates and look forward to progress on measures reflecting other important adult immunizations in the future. Please contact an AVAC manager at (202) 540-1070 or info@adultvaccinesnow.org if you wish to discuss our comments or adult immunization.

Sincerely,

Alliance for Aging Research

American College of Preventive Medicine

Infectious Diseases Society of America

National Association of Chain Drug Stores

National Association of County and City Health Officials

National Foundation for Infectious Diseases

Takeda

The Gerontological Society of America