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.


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