As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the fiscal year 2016 CMS Hospital Outpatient Prospective Payment Proposed Rule (OPPS).
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 healthcare 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 among subscribers.
In this vein, we would like to express our support for maintaining Influenza Vaccination Coverage among Healthcare Personnel (NQF #0431) in the Outpatient Quality Reporting (OQR) Program for the CY 2018 payment determination and subsequent years. Leading medical and health professional associations support influenza vaccination policies for healthcare professionals to help protect patients.1 Healthcare personnel are the first line of defense when it comes to preventing illness and preserving health. Quality measurement reflecting this priority is essential to promoting and advancing prevention in the outpatient healthcare setting and should remain a priority within the Hospital OQR Program.
AVAC also encourages CMS to consider including pneumococcal immunization measures in the OQR program. The health and economic burden of pneumococcal disease, particularly among elderly and high risk adult populations, is significant. Yet, pneumococcal vaccination rates remain inadequate, with only 62 percent of adult over the age of 64 and 20 percent of high risk adults being vaccinated.
Moreover, we urge CMS to consider including additional adult immunization quality measures into the OQR Program in future rulemaking. 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, 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 additional quality measures around immunizations in the Hospital OQR Program would help identify measure gaps, improve upon immunization rates and create greater health outcomes across adult populations.
The FY16 proposed rule also notes intent to develop a comprehensive set of quality measures to be available for widespread use for making informed decisions and quality improvement in the ASC setting. CMS should consider including additional quality measures covering vaccine preventable disease as part of CMS’ future measure selection and development for the ASCQR. 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.
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.