Letters Archive - Page 2 of 12 - Adult Vaccine Access Coalition

AVAC Provides Comments on OMB’s Request for Information

On August 6, AVAC offered comments to the Office of Management and Budget’s Request for Information: Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government. AVAC commented in response to 4 of OMB’s specific areas: Area 1: Holistic and program- or policy-specific assessments of equity for public sector entities; Area 2: Remedying barriers, burdens, and inequities in public service delivery access; Area 4: Assessing equity in procurement and contracting processes; and Area 5: Accessible and meaningful agency engagement with underserved communities.

Letters to Administration

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Dear Deputy Director Young,

The Adult Vaccine Access Coalition (AVAC) welcomes the opportunity to respond to the Request for Information posed by the Office of Management and Budget (OMB). We recognize the importance of equitable access to health care and are committed to far-reaching policies, programs, and partnerships that increase equitable service delivery.

AVAC consists of over 60 organizational leaders in health and public health that are committed to driving federal policy changes that will strengthen and enhance access to adult vaccines and awareness of the importance of adult immunization. AVAC works towards common legislative and regulatory solutions through 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.

Even before the COVID-19 pandemic, vaccine preventable illness devastated the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine-preventable diseases while adult coverage has lagged Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography.

The COVID-19 pandemic has brought these inequities to the forefront, with the CDC reporting as of June 7, that of the 57% of recipients disclosing their ethnicity when receiving their COVID-19 vaccine, 61% were White, 9% were Black, 15% were Hispanic, and 6% were Asian. The relatively low representation of ethnic minorities among COVID-19 vaccine recipients is the most recent example of disparities in vaccination coverage across socio-economic strata. While the pandemic has brought attention to these disparities, the unfortunate reality is that they are not new. Inequities in vaccination rates of minority communities are seen across numerous preventive vaccines. Further, lack of access to care sites has contributed to lower immunization rates in rural compared to urban areas. The impact of immunization on population health is well known, and ensuring that all populations, including the most vulnerable, have access to vaccination is a critical step in ensuring equitable primary health care.

OMB has requested comments on “methods for assessing whether agency policies and actions (e.g., programs, services, processes, and operations) equitably serve all eligible individuals and communities, particularly those that are currently and historically underserved”. AVAC has provided comments in response to 4 of OMB’s specific areas of feedback in greater detail below:

Area 1: Holistic and program- or policy-specific assessments of equity for public sector entities;
Area 2: Remedying barriers, burdens, and inequities in public service delivery access;
Area 4: Assessing equity in procurement and contracting processes;
Area 5: Accessible and meaningful agency engagement with underserved communities.

Area 1: Holistic and program- or policy-specific assessments of equity for public sector entities

To ensure equity in all public sector policies and programs, thorough assessment is required to identify areas of weakness and monitor the progress of proposed solutions. To conduct such assessments, it is critical to have robust monitoring infrastructure, committees, and processes in place. To this end, AVAC suggests the following steps to assess equity in access to vaccinations:

Assess equity in vaccination rates among beneficiaries of public insurance programs to understand areas of inequity that can be addressed through policy changes. Currently, over a quarter of the U.S. population relies on a public program for health coverage, and thus the government represents a significant access point for preventive services. In 2016, immunization rates for Medicaid beneficiaries were up to 12% lower than for commercially insured patients. Inequalities of immunization access persist for our nation’s most vulnerable population that will require additional investigation to properly assess and address.
Invest in improving Immunization Information Systems (“IIS”) to more effectively track and assess inequities in immunization uptake. The CDC and other public health stakeholders must compile vaccination records from a range of IIS across states and jurisdictions in order to depict a comprehensive picture of vaccine coverage and uptake. AVAC strongly supports modernizing and strengthening the capabilities of IIS to capture and share vaccination information in a uniform way. Robust IIS data capture and reporting are critical to understanding patterns in vaccination rates, including disparities by race, socioeconomic status, insurance type, and/or region that perpetuate health inequities.
Encouraging the COVID-19 Health Equity Task Force to transition into a permanent task force that includes a focus on vaccination. This multi-agency and multi-disciplinary Task Force was established to provide specific recommendations to the Administration for mitigating inequities caused or exacerbated by the pandemic. It continues to be essential that all communities have equitable access to COVID-19 vaccinations and booster shots. It is also critical that individuals get caught-up on routine and recommended vaccinations, particularly as students return to in person learning, adults return to the workplace, and people of all ages begin socializing in groups. We recommend that this Task Force continue its work, with an additional goal of on recovering and sustaining high vaccination rates for all vaccines.

Area 2: Remedying barriers, burdens, and inequities in public service delivery access

Multiple barriers to vaccine access remain in the US and disproportionately affect low-income populations who rely on public programs and coverage through Medicare, Medicaid, and those with subsidized commercial insurance. Systemically addressing barriers to vaccine access and promoting culturally competent service delivery can generate vaccine acceptance and demand among at-risk and underserved communities and, ultimately, better protect them against vaccine-preventable diseases. AVAC urges OMB to consider the following steps to address the barriers to vaccine access that perpetuate health inequities:

Utilize health literacy reviews of all vaccine-related information released by the Administration to ensure information is accessible. The Administration routinely publishes critical vaccine-related information. Oftentimes these materials are not written in a reader-centered manner, leading to a lack of understanding among patients and potential missed vaccination opportunities. There is an outstanding need to ensure that all patients can access and understand the policies and requirements that impact their access to healthcare. To that end, we recommend implementing health literacy reviews for all vaccine-related information released by the Administration to ensure that published material is reader-centered and easily understood.

Area 4: Assessing equity in the administration of agency grant programs and other forms of financial assistance

Grant programs and other forms of financial assistance are critical to immunization service delivery and present an important means to promote equitable access and uptake of vaccination. It is critical that immunization-related grant programs both promote vaccine equity and are administered equitably. AVAC recommends the following process changes to promote immunization equity via public sector grant programs and financial assistance:

Conduct a systematic review of all grants that use or could incorporate vaccine equity. The American Rescue Plan and Coronavirus Response and Relief Supplemental Appropriations Act direct funds to promoting COVID-19 vaccine access, acceptance, and uptake among racial and ethnic minority communities. Despite these efforts, vaccination uptake in some communities remains lower than others, suggesting a need for sustained outreach. Future ARP related immunization grants issued should be prioritized based on their ability to successfully promote vaccination to underserved communities. This assessment should be made public so that best practices can be implemented across the country.

Area 5: Accessible and meaningful agency engagement with underserved communities

Achieving equity in immunization access and uptake requires a thorough understanding of the unique needs and access barriers experienced by at-risk and underserved communities. This understanding can only be gained through direct engagement. It then must be applied to create culturally competent, tailored solutions that meet communities’ specific needs. AVAC recommends the following community engagement initiatives:

Engage community-based organizations to identify policy changes that can improve access and uptake of vaccinations. To ensure representation of community voices in the National Vaccine Program planning and execution processes, AVAC recommends the establishment of a community advisory subcommittee that could be formed under the National Vaccine Advisory Committee (NVAC). This advisory group consisting of representatives from community-based organizations could be directed to review and recommend additional vaccine equity goals for federally supported immunization programs, review progress toward those goals, and recommend policy changes to improve equity in access and uptake.

We appreciate the opportunity to provide our perspective on the federal government’s methods to equitably reach all eligible individuals with life-saving vaccines. We would be happy to answer any questions or provide additional information. Please contact an AVAC manager.

AIRA
Alliance for Aging Research
American Lung Association
Association of Asian Pacific Community Health Organizations (AAPCHO)
GSK
Immunization Action Coalition
March of Dimes
Merck
National Viral Hepatitis Roundtable
STChealth
The Gerontological Society of America
Trust for America’s Health

AVAC Provides Feedback for the Development of 21st Century CURES 2.0

AVAC sent a letter to Reps DeGette and Upton with recommendations on the 21st Century CURES 2.0 Act that is currently under development. In the letter, AVAC urges for the inclusion of multiple items, such as making vaccine regulatory flexibilities and authorities granted during the public health emergency permanent and increasing resources available to vaccine and immunization programs.

Letters to Congress

Eliminating Disparities Reducing Financial Barriers Vaccine Infrastructure

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To Representatives DeGette and Upton:

The Adult Vaccine Access Coalition (AVAC) appreciates the opportunity to provide feedback that will help shape and inform the development of 21^st Century Cures 2.0. We greatly appreciate your years of leadership in federal policymaking aimed at accelerating innovations in clinical research and trials as well as improving processes that will expediate access to breakthrough therapies, treatments, and technologies. We are also grateful that your draft legislation calls attention to the public health challenges that have become apparent over the course of the COVID-19 pandemic and offers some meaningful solutions.

AVAC consists of over 60 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 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 to and utilization of adult immunizations.

As you know, immunizations are a highly cost-effective form of preventive medicine that help save lives by protecting the health and wellbeing of individuals and families in communities nationwide. Over the last decade, advancements in technology, policy, and infrastructure have strengthened the immunization landscape. However, the COVID-19 pandemic put a tremendous strain on our chronically underfunded public health infrastructure and exposed important weaknesses that simply must be addressed. We must apply the lessons learned and integrate best practices as we work together to ensure the tools and capabilities necessary to swiftly and confidently respond to future disease outbreaks, pandemics, or disasters are in place.

Section 104. Vaccine and Immunization Programs: We are incredibly grateful that the CURES 2.0 Act recognizes the need for additional resources to bolster immunization awareness efforts and infrastructure. Specifically, the draft authorizes $25 million for an awareness campaign to educate the public with respect to the safety and importance of vaccines and an additional $25 million to strengthen immunization infrastructure systems (IIS). These resources for vitally important to the long-term success of COVID-19 vaccination efforts as well as routine immunization catch up activities that are necessary preserve and protect the health of individuals, families and entire communities.

AVAC urges you to consider also incorporating provisions included in bipartisan legislation, theImmunization Infrastructure Modernization Act (HR550).

While most health departments have immunization infrastructure in place, we learned during the pandemic that the data collection and reporting capabilities of these systems varied greatly. We must ensure that Immunization Information systems (IIS) can meet certain basic security, data collection and reporting standards if we are going to be able to have real-time reporting of reliable immunization information during the next disease outbreak or pandemic.

In addition to funding, Congress has an important leadership role to play in advancing a federal policy framework to help guide IIS modernization investments in terms of the capacity and breadth of these systems, as well as establishing clear goals, expectations and outcomes. As Congress continues to make investments in immunization information system modernization efforts, ensuring these systems can be relied upon to consistently collect and report accurate immunization record data securely and in real-time is essential not only for the next pandemic but also for routine immunization activities.

IIS are computerized, multi-faceted systems that operate in 62 jurisdictions, and have the ability to maintain immunization records across the lifespan. They can be used by providers to order vaccines and track inventory, view a patient’s vaccine history to ensure they are fully vaccinated but not over-vaccinated, remind patients when they are due to receive a recommended vaccine, and, at a population level, track coverage and identify areas where there are low immunization rates so public health programs can develop targeted immunization efforts in response.

However, the pandemic laid bare the fact that IIS capabilities vary across states and many systems were in woefully need of modernization to adequately meet the challenges of a COVID-19 mass vaccination campaign. These systems are vital to public health efforts to track coverage and identify areas where there are low immunization rates so targeted immunization outreach and education efforts can be developed in response. Without investments in immunization infrastructure – IIS in particular – the racial and geographic disparities in vaccination take-up rates are hard to track and address.

We ask that you look to the framework set out in the “IIS Modernization Act, H.R. 550²” for added guidance on how to enhance systems to manage both routine immunization efforts and outbreaks of other vaccine preventable diseases. Among other things, the bill includes the following provisions:

An assessment of current capabilities and gaps among immunization providers;
Expand enrollment and training of immunization providers;
Support real-time immunization record data exchange and reporting;
Improve secure data collection, transmission, bidirectional exchange, maintenance, and analysis of immunization information;
Enhance security of bidirectional exchange of immunization record data and interoperability of immunization information systems with health information technology platforms; and
Enhance data exchange interoperability with other jurisdictions.

Section 402. Strategies to Increase Access to Telehealth under Medicaid and Children’s Health Insurance Program and Section 403. Extending Medicare Telehealth Flexibilities.

The CURES 2.0 Act takes important steps to advance policies to integrate telehealth into public health insurance programs. The provisions affirm the use of telehealth services and enable opportunities for additional health care providers and sites to utilize telehealth services in the provision of care. The COVID-19 pandemic accelerated the adoption of telehealth services and provided access to care at a time when in person visits were not possible. AVAC appreciates that your legislation seeks to preserve and expand upon the availability of telehealth services and the many flexibilities that were granted as a result of the public health emergency.

In terms of immunization, AVAC believes that telehealth services can be a valuable tool for primary care providers to conduct patient immunization status assessments and counseling, particularly for complex patients with chronic conditions. Allowing providers to utilize telemedicine to conduct patient outreach, counseling and education on the importance of recommended vaccines not only during pandemics and public health emergencies but also during the course of regular care will help drive improvements in immunization rates across the lifecourse. Emphasizing support for the provision of telehealth services by providers who care for underserved populations will also enable them to improve and expand immunization efforts within their practices.

Additionally, AVAC supports making vaccine regulatory flexibilities and authorities granted during the public health emergency permanent. Allowing for a wide diversity of health care providers and sites of care to offer vaccines enabled rapid deployment of COVID-19 vaccines to millions of Americans. AVAC urges you to consider including policies that created more access points across communities for immunization and assured health care providers that they would be compensated for vaccine services. We hope Congress will work to extend them beyond the pandemic and to routinely recommended vaccines. Inclusion in the CURES 2.0 Act would be an important step toward that goal.

AVAC appreciates your work and leadership on this important legislation and your consideration of our recommendations. We look forward to working with you throughout the legislative process and stand ready to serve as a resource as you advance this important bipartisan bill.

AVAC Offers Comments on Medicare Program; Hospital Prospective Payment Systems and Quality Programs and Medicare Promoting Interoperability Program Requirements

AVAC sent a letter to the Centers for Medicare & Medicaid Services offering comments on the Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2022 Rates; Quality Programs and Medicare Promoting Interoperability Program Requirements for Eligible Hospitals and Critical Access Hospitals.

Letters to Administration

Appropriations/Funding for Immunization Eliminating Disparities Quality Measures

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To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2022 Rates; Quality Programs and Medicare Promoting Interoperability Program Requirements for Eligible Hospitals and Critical Access Hospitals;

Specifically, AVAC wishes to highlight its strong support for the following proposals included in this proposed rulemaking:

Adoption of a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure beginning With the FY 2023 Hospital IQR program/PCHQR program/LTCHQR program
Maintaining the Influenza Vaccination Coverage Among Healthcare Personnel in the FY23 Hospital IQR Program/PCHQR program/LTCHQR program
Advancing Health Information Exchange through the development of quality measures and implementation of interoperability standards that will facilitate and improve immunization record reporting and real-time information sharing across health care providers, facilities and public health.
Efforts to close the Health Equity Gap and the opportunity to offer our views on important actions that are necessary to address longstanding disparities in adult immunization rates among minority and underserved populations.

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure

AVAC appreciates the opportunity to express its strong support for CMS’ proposal to add a new COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to the FY 2023 Hospital Inpatient Quality Reporting (IQR) Program. The COVID-19 pandemic had a disproportionate and devastating impact on older adults living in long-term care and congregate care settings. This new measure would require hospitals to report on COVID-19 HCP vaccination rates over a shortened period in order to assess whether hospitals are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of hospitals to continue serving their communities throughout the COVID-19 PHE and beyond. Under this proposal, hospitals would report the vaccination data through the Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) beginning October 1, 2021 through December 31, 2021.

AVAC believes this measure is vitally important to protect the health and wellbeing of our community, particularly older adults. Reporting of the COVID-19 for HCP measure through the NHSN will help ensure transparency and accountability in community infection prevention and control efforts and is consistent with other HCP vaccination measures intended to preserve health and mitigate infectious disease outbreaks in the inpatient hospital setting.

We know from reporting of influenza vaccination coverage of HCPs that provider uptake of the vaccine is also associated with that provider recommending vaccination to patients and encourages greater patient vaccination uptake. HCP vaccination can also potentially reduce illness-related missed work and disruptions to patient care. Lastly, reporting of HCP vaccination rates helps inform patients and caregiver choice when considering facilities from which to seek care, particularly for those at high-risk for developing serious complications from COVID–19. While data on the effectiveness of COVID–19 vaccines to prevent asymptomatic infection or transmission is limited, AVAC believes the COVID-19 HCP vaccination measure should nonetheless be included as part of efforts to assess and reduce the risk of transmission of COVID–19 within hospitals and urges CMS to maintain this proposal in the final rule.

The proposed rule includes a shortened reporting period of October through December 2021. AVAC supports the proposed timeframe and appreciates that the COVID-19 HCP reporting period and measure specifications align closely with the Influenza HCP vaccination measure (NQF 0431).

Maintaining the Influenza Vaccination Coverage Among Healthcare Personnel in the FY23 Hospital IQR Program PPS-exempt Cancer Hospital Quality Reporting Program/ Long-term Care Hospitals Quality Reporting Program (LTCHQRP).

AVAC also strongly supports the proposal to maintain the Influenza Vaccination Coverage Among Healthcare Personnel (NQF#0431). This measure plays a critical role in the CMS Quality Strategy as well as the National Quality Strategy in terms of influenza immunization efforts. Ensuring healthcare personnel vaccination adherence against influenza has been shown to improve patient safety and reduce disease transmission, which is essential for immunocompromised patients in the cancer hospital setting.

Empowering patients and caregivers with the ability to assess cancer hospitals based on this measure could ultimately result in improved outcomes for patients through lower complications. Data transparency of reported measures is an important tool for patients and

families seeking to evaluate LTCH settings and an essential component in the identification and management of influenza outbreaks. We support public reporting LTCH QRP data on a CMS website, such as Hospital Compare and support the inclusion of the two above measures in this effort. Tracking vaccine status among health care workers has the ability to increase vaccination rates and reduce absenteeism among healthcare personnel.

Fast Healthcare Interoperability Resources (FHIR) in support of Digital Quality Measurement in Quality Reporting Programs – RFI

AVAC appreciates the work of the Department of Health and Human Services to “encourage and support the adoption of interoperable health information technology and to promote nationwide health information exchange to improve health care and patient access to their health information.” Promoting the use of consistent patient data sets across health care settings can be vitally important to ensure quality patient care and health outcomes while reducing the reporting burden on providers. Additionally, timely and accurate reporting of immunization record data is also of great importance for public health disease surveillance and outbreak prevention activities. Consistent data collection and reporting is a foundational element for successful quality measurement, transparency, and accountability.

AVAC fully supports greater use of electronic clinical quality measures (ecQMs) across health care programs managed by HHS, including the Centers for Medicare and Medicaid Services (CMS), the Health Resources and Services Administration (HRSA), among other agencies. As CMS seeks feedback on definitions for digital quality measures (dQMs) for the Hospital IQR Program, we would encourage CMS to look to existing ecQM resources that are available through the National Coordinator for Health Information Technology6 and as well as uniform data system modernization efforts within the Bureau of Primary Health Care at HRSA. Greater consistency in the adoption and use of electronic quality measures and a common reporting standard8across HHS programs that serve vulnerable populations of all ages and across health care settings will improve overall quality of patient care, drive better health outcomes, as well as inform and empower patients, without creating an additional complexities and reporting burdens on health care providers.

In terms of vaccine data for patients in hospital settings, AVAC supports incentivizing interoperable and bidirectional immunization data reporting to immunization information systems, leveraging tools and measures through the hospital IQR program. As previously stated, provider, patient and caregiver access to immunization record data is essential to addressing health inequities in immunization coverage for the COVID-19, as well as the range of routinely recommended vaccines important to protecting the health and wellbeing of Medicare beneficiaries in inpatient care settings.

Quality measurement programs through Medicare play a critical role in promoting improved quality and encouraging adherence to and consistent utilization of recommended health care interventions, including adult vaccines. Vaccines play a vital role in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. The Department of Health and Human Services (HHS) recognizes that immunization is an important tool to keep people healthy and reduce avoidable health care costs across the lifecourse, especially given the COVID-19 pandemic and annual flu seasons.

Closing the Health Equity Gap in CMS Hospital Quality Programs— Request for Information – RFI

AVAC appreciates the opportunity to respond to the request for information on closing the health equity gap included in the proposed rule. Even before the COVID-19 pandemic, vaccine preventable illness devastated the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Prior to the pandemic more than 50,000 adults died from vaccine-preventable diseases each year in the United States. While adult coverage has lagged behind Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography.

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have eroded further, leaving communities vulnerable to preventable disease, illness, and outbreaks. An analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.1 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates) Long-standing health disparities are also laid bare in these trends. Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 vaccine compared to 53% of white Americans.2 Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population. These trends could have serious consequences for the future, threatening widespread outbreaks of vaccine preventable conditions. We are grateful for CMS’ commitment to addressing systemic inequities that have resulted in poor health outcomes for certain populations.

AVAC urges CMS to promote dissemination and adoption of the National Vaccine Advisory Committee (NVAC) Standards for Adult Immunization Practice1. This standard of practice for immunizations would ensure that Medicare beneficiaries have equitable access to information about recommended vaccines and the opportunity to receive those vaccines from a trusted health care provider. Consistent assessment of immunization status through adoption of NVAC adult standards of care and implementation of adult immunization status measure are vital components to addressing longstanding disparities in access to immunization and will ensure that all Medicare beneficiaries receive a strong immunization recommendation from their provider and have the resources they need to make an informed decision. Widespread implementation of the NVAC Standards for Adult Immunization Practice is also an important first step toward advancing the Healthy People 2030 developmental measure to increase the proportion of adults age 19 or older who get recommended vaccines (IID-D03).

interoperability, bidirectional exchange, data quality and security. AVAC encourages CMS to work with the HHS Office of Disease Prevention and Health Promotion to include the Healthy People 2030 developmental goal to increase the proportion of people with vaccine records in an IIS in its strategy to close equity gaps for adult immunization. Robust immunization record data reporting will empower providers, patients and caregivers to make educated decisions about vaccinations, reduce missed opportunities for immunization and minimize the likelihood of overvaccination, and help inform health care system efforts to close health equity gaps and prevent disease outbreaks.

Lastly, AVAC also expresses support for the use of Quality Improvement Networks and Quality Improvement Organizations (QIN-QIOs) as a means to address the core priority areas outlined in the CMS Equity Plan for Improving Quality in Medicare. The three priority areas which inform CMS policies and programs are: (1) Increasing understanding and awareness of health disparities; (2) developing and disseminating solutions to achieve health equity; and (3) implementing sustainable actions to achieve health equity. The QIN-QIOs have a demonstrated track record of success in testing and evaluating innovative and effective strategies for improving immunization coverage rates among targeted Medicare populations.5 AVAC encourages CMS to continue to utilize the QIN-QIOs for this purpose and urges CMS to include in the list of tasks outlined in future scopes of work (SOW) strategies to improve immunization coverage rates among hard to reach rural and geographically underserved areas as well as among disabled, homebound, inpatient and congregate care patient populations.

Thank you again for the opportunity to share our perspective on this proposed rule. Please contact an AVAC Coalition Manager at (202) 540-1070 or lfoster@adultvaccinesnow.org if you wish to further discuss our comments. To learn more about the work of AVAC visit www.adultvaccinesnow.org.

Sincerely,

AIRA
Alliance for Aging Research
Association of Asian Pacific Community Health Organizations (AAPCHO)
GSK
Immunization Action Coalition
Infectious Diseases Society of America
Kimberly Coffey Foundation
National Foundation for Infectious Diseases
Sanofi
Seqirus
STChealth
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family

AVAC Offers Comments on the Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2022

AVAC managers sent a letter to the Centers for Medicare & Medicaid Services offering comments on the Medicare Program: Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2022.

Letters to Administration

Appropriations/Funding for Immunization Eliminating Disparities Quality Measures

Download

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1746-P
P.O. Box 8016
Baltimore, MD 21244-8016

To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program and Value-Based Purchasing Program for Federal Fiscal Year 2022.

Specifically, AVAC wishes to highlight its strong support for the following proposals included in this proposed rulemaking:

Efforts to close the Health Equity Gap and the opportunity to offer our views on important actions that are necessary to address longstanding disparities in adult immunization rates among minority and underserved populations.
Adoption of a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure.
Advancing Health Information Exchange through the development of quality measures and implementation of interoperability standards that will facilitate and improve immunization record reporting and real-time information sharing across health care providers, facilities and public health.
Inclusion of the Adult Immunization Status (AIS) measure in an expanded SNF VBP Program.

Closing the Health Equity Gap – RFI

AVAC appreciates the opportunity to respond to the request for information on closing the health equity gap included in the proposed rule. Even before the COVID-19 pandemic, vaccine preventable illness devastated the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine-preventable diseases while adult coverage has lagged behind Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography.

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have eroded further, leaving communities vulnerable to preventable disease, illness, and outbreaks. An analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.4 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates).5 Long-standing health disparities are also laid bare in these trends. Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 vaccine compared to 53% of white Americans. Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population. These trends could have serious consequences for the future, threatening widespread outbreaks of vaccine preventable conditions. We are grateful for CMS’ commitment to addressing systemic inequities that have resulted in poor health outcomes for certain populations. We commend CMS for finalizing in the FY2020 SNF PPS final rule the adoption of standardized patient assessment data elements (SPADEs) that include several social determinants of health (SDOH) and appreciate the opportunity to offer recommendations for expanded measurement and data collection that will help address gaps in health equity with respect to immunizations.

Immunization status measure is a vital component to addressing longstanding disparities in access to immunization and will ensure that all Medicare beneficiaries receive a strong immunization recommendation from their provider and have the resources they need to make an informed decision. Widespread implementation of the NVAC Standards for Adult Immunization Practice is also an important first step toward advancing the Healthy People 2030 developmental measure to increase the proportion of adults age 19 or older who get recommended vaccines (IID-D03).

Another important element to closing the equity gap is consistent data collection and real-time reporting. The COVID-19 pandemic has illustrated the need for investments in our nationwide immunization data framework, as well as the dissemination and adoption of federal guidelines and incentives to encourage consistent reporting and widespread utilization of immunization information systems (IIS) across provider settings. In order to effectively identify and address health equity gaps, there must be strong and clear criteria in place for data reporting elements, provider usage, along with baseline standards interoperability, bidirectional exchange, data quality and security. AVAC encourages CMS to work with the HHS Office of Disease Prevention and Health Promotion to include the Healthy People 2030 lifespan IIS reporting3 developmental measure in its strategy to close equity gaps for adult immunization. Robust immunization record data reporting will empower providers, patients and caregivers to make educated decisions about vaccinations, reduce missed opportunities for immunization and minimize the likelihood of overvaccination, and help inform health care system efforts to close health equity gaps and prevent disease outbreaks.

targeted Medicare populations. AVAC encourages CMS to continue to utilize the QIN-QIOs for this purpose and urges CMS to include in the list of tasks outlined in future scopes of work (SOW) strategies to improve immunization coverage rates among hard to reach rural and geographically underserved areas as well as among disabled, homebound, inpatient and congregate care patient populations.

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure

AVAC also appreciates the opportunity to express its strong support for CMS’ proposal to add a new COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to the FY 2023 SNF QRP. The COVID-19 pandemic had a disproportionate and devastating impact on older adults living in long-term care and congregate care settings. This new measure would require SNFs to report on COVID-19 HCP vaccination in order to assess whether SNFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of SNFs to continue serving their communities throughout the COVID-19 PHE and beyond. Under this proposal, SNFs would report the vaccination data through the Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) beginning October 1, 2021.

AVAC believes this measure is vitally important to protect the health and wellbeing of older adults in SNFs and reporting of this measure through the NHSN helps to ensure transparency and accountability in community infection prevention and control efforts and is consistent with other HCP vaccination measures intended to preserve health and mitigate infectious disease outbreaks in long-term care settings. We know from reporting of influenza vaccination coverage of HCPs that provider uptake of the vaccine is also associated with that provider recommending vaccination to patients and encourages greater patient vaccination uptake. HCP vaccination can also potentially reduce illness-related missed work and disruptions to patient care. Lastly, reporting of HCP vaccination rates helps inform patients and caregiver choice when considering facilities from which to seek care, particularly for those at high-risk for developing serious complications from COVID–19. While data on the effectiveness of COVID–19 vaccines to prevent asymptomatic infection or transmission is limited, AVAC believes the COVID-19 HCP vaccination measure should nonetheless be included as part of efforts to assess and reduce the risk of transmission of COVID–19 within SNFs and urges CMS to maintain this proposal in the final rule.

Fast Healthcare Interoperability Resources (FHIR) in support of Digital Quality Measurement in Quality Reporting Programs – RFI

AVAC fully supports greater use of electronic clinical quality measures (ecQMs) across health care programs managed by HHS, including the Centers for Medicare and Medicaid Services (CMS), the Health Resources and Services Administration (HRSA), among other agencies. As CMS seeks feedback on definitions for digital quality measures (dQMs) for the SNF Quality Reporting Program (QRP), we would encourage CMS to look to existing ecQM resources that are available through the National Coordinator for Health Information Technology6 and as well as uniform data system modernization efforts within the Bureau of Primary Health Care at HRSA. Greater consistency in the adoption and use of electronic quality measures and a common reporting standard across HHS programs that serve vulnerable populations of all ages and across health care settings will improve overall quality of patient care, drive better health outcomes, as well as inform and empower patients, without creating an additional complexities and reporting burdens on health care providers.

In terms of vaccine data for patients in SNF and long-term care settings, AVAC supports incentivizing interoperable and bidirectional immunization data reporting to immunization information systems, leveraging tools and measures through the SNF QRP. As previously stated, provider, patient and caregiver access to immunization record data is essential to addressing health inequities in immunization coverage for the COVID-19, as well as the range of routinely recommended vaccines important to protecting the health and wellbeing of Medicare beneficiaries in long-term care and SNF settings.

Expanded SNF VBP Program

AVAC is grateful for the opportunity to present its views in response to the proposed rule request for input from stakeholders on quality measures should be considered under an expanded SNF VBP. As the proposed rule notes, the Consolidated Appropriations Act, 2021 allowed the Secretary to expand the SNF VBP program and apply up to ten measures with respect to payments beginning in FY 2024, which may include measures of functional status, patient safety, care coordination, or patient experience.

Adult Immunization Status Measure

As CMS considers a range of measures aimed at the quality of patient care with the goal of improving the overall patient experience and health outcomes, AVAC urges CMS to include of an Adult Immunization Status (AIS) measure in an expanded SNF VBP. The AIS measure is a composite of several age-recommended vaccines for adults, comprising influenza, pneumococcal, zoster, and Tdap vaccines. Adoption of the composite measure will provide a sound, reliable and comprehensive means to assesses the receipt of routinely recommended adult immunizations vital to healthy aging and prevention of avoidable illness. The AIS would reduce the reporting burden on providers while also incentivizing them to follow the National Vaccine Advisory Committee (NVAC) Practice Standards for Adult Immunization Practice1 to assess, recommend, administer or refer and document the vaccines the patient may (or may not) have received.

Several years ago, AVAC released a White Paper outlining the value and imperative of quality measures for adult vaccines.2 The report highlights the role of vaccine quality measures in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. Quality measurement programs through

Medicare play a critical role in promoting improved quality and encouraging adherence to and consistent utilization of recommended adult vaccines.

The addition of an AIS quality measure to the SNF VBP would meet the three core strategies underlying the movement toward a truly patient-centered health care delivery system by: 1) Improving the way clinicians are paid to incentivize quality and value of care over simply quantity of services; 2) improving the way care is delivered by providing clinical practice support, data and feedback reports to guide improvement and better decision-making and; 3) making data more available in real-time at the point of contact and enabling the use of certified Electronic Health Record (EHR) technology and other data sources to support care delivery.

Sincerely,

Lisa Foster, AVAC Manager
Abby Bownas, AVAC Manager

AVAC Offers Comments on the Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program

AVAC managers sent a letter to the Centers for Medicare & Medicaid Services with comments on the Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program.

Letters to Administration

Appropriations/Funding for Immunization Eliminating Disparities Quality Measures

Download

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1748-P
P.O. Box 8016
Baltimore, MD 21244-8016

To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on Medicare Program: Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2022 and Updates to the IRF Quality Reporting Program.

Specifically, AVAC wishes to highlight its strong support for the following proposals included in this proposed rulemaking:

Efforts to close the Health Equity Gap and the opportunity to offer our views on important actions that are necessary to address longstanding disparities in adult immunization rates among minority and underserved populations.
Adoption of a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure beginning With the FY 2023 IRF QRP
Advancing Health Information Exchange through the development of quality measures and implementation of interoperability standards that will facilitate and improve immunization record reporting and real-time information sharing across health care providers, facilities and public health.

Closing the Health Equity Gap – RFI

AVAC appreciates the opportunity to respond to the request for information on closing the health equity gap included in the proposed rule. Even before the COVID-19 pandemic, vaccine preventable illness devastated the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine-preventable diseases while adult coverage has lagged behind Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography.

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have eroded further, leaving communities vulnerable to preventable disease, illness, and outbreaks.2 An analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.4 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates).5 Long-standing health disparities are also laid bare in these trends. Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 vaccine compared to 53% of white Americans.7 Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population.8 These trends could have serious consequences for the future, threatening widespread outbreaks of vaccine preventable conditions. We are grateful for CMS’ commitment to addressing systemic inequities that have resulted in poor health outcomes for certain populations.

First, AVAC urges to CMS to promote dissemination and adoption of the National Vaccine Advisory Committee (NVAC) Standards for Adult Immunization Practice1. This standard of practice for immunizations would ensure that Medicare beneficiaries have equitable access to information about recommended vaccines and the opportunity to receive those vaccines from a trusted health care provider. Assessment of immunization status through adoption of NVAC adult standards of care and implementation of adult Immunization status measure is a vital component to addressing longstanding disparities in access to immunization and will ensure that all Medicare beneficiaries receive a strong immunization recommendation from their provider and have the resources they need to make an informed decision. Widespread implementation of the NVAC Standards for Adult Immunization Practice is also an important first step toward advancing the Healthy People 2030

developmental measure to increase the proportion of adults age 19 or older who get recommended vaccines (IID-D03).2

Lastly, AVAC also expresses support for the use of Quality Improvement Networks and Quality Improvement Organizations (QIN-QIOs) as a means to address the core priority areas outlined in the CMS Equity Plan for Improving Quality in Medicare. The three priority areas which inform CMS policies and programs are: (1) Increasing understanding and awareness of health disparities; (2) developing and disseminating solutions to achieve health equity; and (3) implementing sustainable actions to achieve health equity.4 The QIN-QIOs have a demonstrated track record of success in testing and evaluating innovative and effective strategies for improving immunization coverage rates among targeted Medicare populations.5 AVAC encourages CMS to continue to utilize the QIN-QIOs for this purpose and urges CMS to include in the list of tasks outlined in future scopes of work (SOW) strategies to improve immunization coverage rates among hard to reach rural and geographically underserved areas as well as among disabled, homebound, inpatient and congregate care patient populations.

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure

require SNFs to report on COVID-19 HCP vaccination in order to assess whether SNFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of IRFs to continue serving their communities throughout the COVID-19 PHE and beyond. Under this proposal, IRFs would report the vaccination data through the Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) beginning October 1, 2021.

AVAC believes this measure is vitally important to protect the health and wellbeing of older adults in IRFs and reporting of this measure through the NHSN helps to ensure transparency and accountability in community infection prevention and control efforts and is consistent with other HCP vaccination measures intended to preserve health and mitigate infectious disease outbreaks in long-term care settings. We know from reporting of influenza vaccination coverage of HCPs that provider uptake of the vaccine is also associated with that provider recommending vaccination to patients and encourages greater patient vaccination uptake. HCP vaccination can also potentially reduce illness-related missed work and disruptions to patient care. Lastly, reporting of HCP vaccination rates helps inform patients and caregiver choice when considering facilities from which to seek care, particularly for those at high-risk for developing serious complications from COVID–19. While data on the effectiveness of COVID–19 vaccines to prevent asymptomatic infection or transmission is limited, AVAC believes the COVID-19 HCP vaccination measure should nonetheless be included as part of efforts to assess and reduce the risk of transmission of COVID–19 within IRFs and urges CMS to maintain this proposal in the final rule.

Fast Healthcare Interoperability Resources (FHIR) in support of Digital Quality Measurement in Quality Reporting Programs – RFI

Administration (HRSA), among other agencies. As CMS seeks feedback on definitions for digital quality measures (dQMs) for the IRF Quality Reporting Program (QRP), we would encourage CMS to look to existing ecQM resources that are available through the National Coordinator for Health Information Technology6 and as well as uniform data system modernization efforts within the Bureau of Primary Health Care at HRSA.7 Greater consistency in the adoption and use of electronic quality measures and a common reporting standard8across HHS programs that serve vulnerable populations of all ages and across health care settings will improve overall quality of patient care, drive better health outcomes, as well as inform and empower patients, without creating an additional complexities and reporting burdens on health care providers.

In terms of vaccine data for patients in SNF and long-term care settings, AVAC supports incentivizing interoperable and bidirectional immunization data reporting to immunization information systems, leveraging tools and measures through the IRF QRP. As previously stated, provider, patient and caregiver access to immunization record data is essential to addressing health inequities in immunization coverage for the COVID-19, as well as the range of routinely recommended vaccines important to protecting the health and wellbeing of Medicare beneficiaries in long-term care and IRF settings.

Sincerely,

Lisa Foster, AVAC Manager
Abby Bownas, AVAC Manager

AVAC Offers Comments on the FY 2022 Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Updates

AVAC managers submitted a letter to the Centers for Medicare and Medicaid outlining areas of support and offering comments for several proposals under the proposed rulemaking for the Medicare program FY 2022 Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Updates for Fiscal Year Beginning October 1, 2021.

Letters to Administration

Appropriations/Funding for Immunization Eliminating Disparities Quality Measures

Download

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1750-P
P.O. Box 8010
Baltimore, MD 21244-8016

To Whom It May Concern:

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on Medicare Program: FY 2022 Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Updates for Fiscal Year Beginning October 1, 2021

Specifically, AVAC wishes to highlight its strong support for the following proposals included in this proposed rulemaking:

Efforts to close the Health Equity Gap and the opportunity to offer our views on important actions that are necessary to address longstanding disparities in adult immunization rates among minority and underserved populations.
Adoption of a COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure.
Maintaining the Influenza Immunization (NQF #1659) and urges consideration of the Adult Immunization Status (AIS) measure in future rulemaking on IPFQR measures.

Closing the Health Equity Gap – RFI

the lives of thousands of adults each year, particularly older adults and those with underlying health conditions. Vaccine preventable conditions not only affect the patient but also their family members, caregivers and friends. Despite the well-known benefits of immunizations, more than 50,000 adults die from vaccine-preventable diseases while adult coverage has lagged behind Healthy People targets for most commonly recommended vaccines. Disparities in adult vaccination coverage rates are even more acute when broken down by age, race, ethnicity, socioeconomic status and geography.

Unfortunately, as result of the pandemic, routine vaccination rates, across all ages, have eroded further, leaving communities vulnerable to preventable disease, illness, and outbreaks.2 An analysis found that adult and adolescent CDC recommended vaccines declined between 41%-53% from March-August 2019 as compared to March-August 2020.4 Weekly vaccination rates among Medicare beneficiaries also declined drastically (70%–89% below 2019 rates).5 Long-standing health disparities are also laid bare in these trends. Further, data indicate that 35% of Black Americans and 42% of Hispanic Americans report wanting to receive the COVID-19 vaccine compared to 53% of white Americans.7 Meanwhile, Black Americans and Hispanic Americans are proportionally receiving less COVID-19 vaccinations than their share of the total population.8 These trends could have serious consequences for the future, threatening widespread outbreaks of vaccine preventable conditions. We are grateful for CMS’ commitment to addressing systemic inequities that have resulted in poor health outcomes for certain populations.

First, AVAC urges to CMS to promote dissemination and adoption of the National Vaccine Advisory Committee (NVAC) Standards for Adult Immunization Practice1. This standard of practice for immunizations would ensure that Medicare beneficiaries have equitable access to information about recommended vaccines and the opportunity to receive those vaccines from a trusted health care provider. Assessment of immunization status through adoption of NVAC adult standards of care and implementation of adult Immunization status measure is a vital component to addressing longstanding disparities in access to immunization and will ensure that all Medicare beneficiaries receive a strong immunization recommendation from their provider and have the resources they need to make an informed decision. Widespread implementation of the NVAC Standards for Adult Immunization Practice is also an important first step toward advancing the Healthy People 2030 developmental measure to increase the proportion of adults age 19 or older who get recommended vaccines (IID-D03).2

Another important element to closing the equity gap is consistent data collection and real-time reporting. The COVID-19 pandemic has illustrated the

need for investments in our nationwide immunization data framework, as well as the dissemination and adoption of federal guidelines and incentives to encourage consistent reporting and widespread utilization of immunization information systems (IIS) across provider settings. In order to effectively identify and address health equity gaps, there must be strong and clear criteria in place for data reporting elements, provider usage, along with baseline standards interoperability, bidirectional exchange, data quality and security. AVAC encourages CMS to work with the HHS Office of Disease Prevention and Health Promotion to include the Healthy People 2030 lifespan IIS reporting3 developmental measure in its strategy to close equity gaps for adult immunization. Robust immunization record data reporting will empower providers, patients and caregivers to make educated decisions about vaccinations, reduce missed opportunities for immunization and minimize the likelihood of overvaccination, and help inform health care system efforts to close health equity gaps and prevent disease outbreaks.

Lastly, AVAC also expresses support for the use of Quality Improvement Networks and Quality Improvement Organizations (QIN-QIOs) as a means to address the core priority areas outlined in the CMS Equity Plan for Improving Quality in Medicare. The three priority areas which inform CMS policies and programs are: (1) Increasing understanding and awareness of health disparities; (2) developing and disseminating solutions to achieve health equity; and (3) implementing sustainable actions to achieve health equity.4 The QIN-QIOs have a demonstrated track record of success in testing and evaluating innovative and effective strategies for improving immunization coverage rates among targeted Medicare populations.5 AVAC encourages CMS to continue to utilize the QIN-QIOs for this purpose and urges CMS to include in the list of tasks outlined in future scopes of work (SOW) strategies to improve immunization coverage rates among hard to reach rural and geographically underserved areas as well as among disabled, homebound, inpatient and congregate care patient populations.

COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure

AVAC also appreciates the opportunity to express its strong support for CMS’ proposal to add a new COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) Measure to the FY 2023 SNF QRP. The COVID-19 pandemic had a disproportionate and devastating impact on older adults. This new measure would require IPFs to report on COVID-19 HCP vaccination in order to assess whether IPFs are taking steps to limit the spread of COVID-19 among their HCP, reduce the risk of transmission within their facilities and help sustain the ability of IPFs to continue serving their communities throughout the COVID-19 PHE and beyond. Under this proposal, IPFs would report the vaccination data

through the Centers for Disease Control and Prevention National Healthcare Safety Network (NHSN) beginning October 1, 2021.

AVAC believes this measure is vitally important to protect the health and wellbeing of Medicare beneficiaries in IPFs and reporting of this measure through the NHSN helps to ensure transparency and accountability in community infection prevention and control efforts and is consistent with other HCP vaccination measures intended to preserve health and mitigate infectious disease outbreaks. We know from reporting of influenza vaccination coverage of HCPs that provider uptake of the vaccine is also associated with that provider recommending vaccination to patients and encourages greater patient vaccination uptake. HCP vaccination can also potentially reduce illness-related missed work and disruptions to patient care. Lastly, reporting of HCP vaccination rates helps inform patients and caregiver choice when considering facilities from which to seek care, particularly for those at high-risk for developing serious complications from COVID–19. While data on the effectiveness of COVID–19 vaccines to prevent asymptomatic infection or transmission is limited, AVAC believes the COVID-19 HCP vaccination measure should nonetheless be included as part of efforts to assess and reduce the risk of transmission of COVID–19 within IPFs and urges CMS to maintain this proposal in the final rule.

IPF Quality Reporting Program (IPFQRP) Immunization measures

AVAC appreciates the proposed rule maintains Influenza Immunization (NQF #1659) for the Inpatient Psychiatric Facilities (IPF) Quality Reporting Program prescribed in the rule. AVAC urges CMS to maintain the measure in the final rule. Quality measures play a critical role in the CMS Quality Strategy as well as the National Quality Strategy in terms of influenza immunization efforts. The Department of Health and Human Services Strategic Plan FY 2018 –2022, encourages the use of age-appropriate vaccines to minimize the burden of vaccine-preventable diseases across the life span4. Quality measurement programs through Medicare promote improved quality and encourage adherence to and consistent utilization of recommended health care interventions, including adult vaccines.

Vaccines play a vital role in preventing illness and death, reducing caregiving demands, avoiding unnecessary healthcare spending, and setting the foundation for healthy aging. The Department of Health and Human Services (HHS) recognizes that immunization is an important tool to keep people healthy and reduce avoidable health care costs across the lifecourse, especially given the COVID-19 pandemic and annual flu seasons. Maintenance of the Influenza Immunization measure will help protect lives, prevents morbidity and mortality and saves health care costs.

In future rulemaking, AVAC urges CMS to consider inclusion of an Adult Immunization Status (AIS) measure in the IPFQRP. The AIS measure is a composite of several age-recommended vaccines for adults, comprising influenza, pneumococcal, zoster, and Tdap vaccines. Adoption of the composite measure aligns with CMS efforts to improve the quality of patient care, the overall patient experience and health outcomes. It would also provide a sound, reliable and comprehensive means to assesses the receipt of routinely recommended adult immunizations vital to healthy aging and prevention of avoidable illness. The AIS would reduce the reporting burden on providers while also incentivizing them to follow the National Vaccine Advisory Committee (NVAC) Practice Standards for Adult Immunization Practice1 to assess, recommend, administer or refer and document the vaccines the patient may (or may not) have received.

The addition of an AIS quality measure to the IPFQRP would meet the three core strategies underlying the movement toward a truly patient-centered health care delivery system by: 1) Improving the way clinicians are paid to incentivize quality and value of care over simply quantity of services; 2) improving the way care is delivered by providing clinical practice support, data and feedback reports to guide improvement and better decision-making and; 3) making data more available in real-time at the point of contact and enabling the use of certified Electronic Health Record (EHR) technology and other data sources to support care delivery.

Sincerely,

Lisa Foster, AVAC Manager
Abby Bownas, AVAC Manager

AVAC Leads a Letter in Support of the Protecting Seniors Through Immunization Act

AVAC led over 80 stakeholders in sending a letter to Congress urging support of the Protecting Seniors Through Immunization Act (S.912/H.R.1978), a bill that helps strengthen vaccine uptake by improving education and equitable access to recommended vaccines for Medicare beneficiaries.

Letters to Congress

Eliminating Disparities Reducing Financial Barriers

download

May 27, 2021

Dear Majority Leader Schumer, Speaker Pelosi, and Minority Leaders McConnell and McCarthy:

During Older Americans Month, we, the undersigned organizations that care about healthy aging, write to offer our strong support for the Protecting Seniors Through Immunization Act (S. 912/H.R. 1978). This bipartisan, bicameral legislation, led by Senators Hirono, Capito, Whitehouse, and Scott, and Representatives Kuster and Bucshon is especially important in the wake of coronavirus public health crisis.

Prior to the COVID-19 pandemic, more than 50,000 adults died from vaccine-preventable diseases each year. Millions more suffer the health effects of those diseases, causing them to miss work to care for themselves or others and leaving them unable to engage in their routine activities. The COVID-19 pandemic has exacerbated this, causing adults to delay or avoid interactions with the health care system for preventative services. A component of combatting COVID-19 is a wider adoption of preventive health strategies to reduce the burden of co-morbid conditions that put people at higher risk of worse outcomes of COVID-19. Immunizing against all vaccine-preventable diseases will both contribute to better health outcomes overall and preserve vital capacity at hospitals by reducing preventable admissions. Despite the well-known benefits of immunization, adult coverage lagged behind federal targets for most commonly recommended vaccines.

The Protecting Seniors Through Immunization Act will help strengthen vaccine uptake by improving education and equitable access to recommended vaccines for Medicare beneficiaries. It will bring much needed parity to the out-of-pocket payment required of Medicare beneficiaries for vaccines covered under Part B and Part D. Copayments apply only to vaccines covered under Medicare Part D (tetanus-diphtheria-acellular pertussis (Tdap) and varicella zoster (shingles)), and vary widely across plans. Immunizations should be available with no cost to the beneficiary in the same way vaccines are covered under Part B (Covid-19, flu, pneumococcal). Removing this barrier will provide a direct financial and health benefit for people age 65 and over and will help to improve our national preparedness among the Medicare population.

Thank you for your consideration of support.

Sincerely,

Adult Vaccine Access Coalition

Alliance for Aging Research

Alliance for Immunizations in Michigan

Alliance for Patient Access

American Academy of Family Physicians

American Association of Occupational Health Nurses (AAOHN)

American Behcet’s Disease Association (ABDA)

American College of Preventive Medicine (ACPM)

American Federation of State, County and Municipal Employees (AFSCME)

American Immunization Registry Association (AIRA)

American Kidney Fund

American Lung Association

American Pharmacists Association (APhA)

American Public Health Association (APHA)

American Society on Aging

Answer2Cancer

Association of Asian Pacific Community Health Organizations (AAPCHO)

Association of Immunization Managers (AIM)

Association for Professionals in Infection Control and Epidemiology (APIC)

Asian & Pacific Islander American Health Forum (APIAHF)

AstraZeneca

Biotechnology Innovation Organization (BIO)

California Immunization Coalition

CancerCare

Caregiver Action Network

Caring Ambassadors Program

Coalition of Wisconsin Aging and Health Groups

COPD Foundation

Dynavax

Families Fighting Flu

Generations United

Geriatric Medicine Pas

Global Healthy Living Foundation

GSK

HealthHIV

HealthyWomen

Hep B United

Hepatitis B Foundation

Idaho Immunization Clinic

Immunization Action Coalition (IAC)

Immunize Colorado

Immunize Nevada

Immunize Ohio

ImmunizeTN

Infectious Diseases Society of America (IDSA)

Justice in Aging

KelseyCare Advantage

Kelsey-Seybold Clinic Clinic

Kimberly Coffey Foundation

Lupus and Allied Diseases Association, Inc.

Lupus Foundation of America

Medical University of South Carolina

Medicago

Merck

Moderna

National Association of County and City Health Officials (NACCHO)

National Association of Nutrition and Aging Services Programs (NANASP)

National Black Nurses Association (NBNA)

National Caucus and Center on Black Aging

National Coalition for LGBT Health

National Consumers League

National Council of Asian Pacific Islander Physicians (NCAPIP)

National Education Association (NEA)

National Foundation for Infectious Diseases (NFID)

National Grange

National Hispanic Medical Association (NHMA)

National Viral Hepatitis Roundtable (NVHR)

Novavax

Patient Access Network (PAN) Foundation

Pfizer

Physician Assistants in Hospice and Palliative Medicine (PAHPM)

Pennsylvania Immunization Coalition

RetireSafe

Sanofi

Scientific Technologies Corporation (STC)

Service Employees International Union (SEIU)

The AIDS Institute

The Arizona Partnership for Immunization

The Gerontological Society of America (GSA)

The Immunization Partnership

Triage Cancer

Trust for America’s Health

Tulsa Area Immunization Coalition

University of Pennsylvania

Vaccinate Your Family

Vaccine Ambassadors

Valneva

WomenHeart: The National Coalition for Women with Heart Disease

Women Impacting Public Policy (WIPP)

AVAC Supports the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act

AVAC wrote Senators Hassan and Cassidy to express strong support for their leadership on the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act. Vaccines are crucial for protecting mothers and their babies, yet many pregnant women remain unvaccinated. The Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act will both modernize and increase maternal vaccination rates among the perinatal population.

Letters to Congress

Eliminating Disparities Reducing Financial Barriers

Download

Dear Senators Hassan and Cassidy,

We write to express our strong support for the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act. We appreciate your leadership around modernizing and improving maternal immunization rates.

Since 2004, the Advisory Committee on Immunization Practices (ACIP) has issued recommendations on the importance of maternal immunization, and currently recommends that all pregnant women receive the influenza, tetanus toxoid, reduced diphtheria toxoid, and acellular pertussis (Tdap) vaccines. Unfortunately, a recent survey by the Centers for Disease Control and Prevention (CDC) found that “many pregnant women are unvaccinated, and they and their babies continue to be vulnerable to influenza and pertussis infection and potentially serious complications including hospitalization and death.”

Pregnant women seeking access to and coverage for vaccines encounter multiple barriers, including lack of information about recommended vaccines, financial hurdles, and technological and logistical obstacles. Additionally, vaccine confidence and hesitancy issues remain a challenge. Your legislation seeks to change this and would help improve access to and utilization of maternal vaccines by ensuring first dollar coverage of vaccines for perinatal women enrolled in Medicaid; adopting the recent prenatal immunization quality measure; and requesting much sought-after data on obstetric patients and providers.

As immunizations are a highly cost-effective form of preventive medicine that help save lives by protecting the health and wellbeing of individuals and families in communities nationwide, it is in our nation’s interest to improve immunization coverage rates as a means to improve maternal health outcomes. With several promising new vaccines in the research pipeline for life threatening conditions that could provide important health benefits to pregnant women and their children, now is the time to focus on improving immunization rates in the perinatal population.

Again, thank you for leadership on the Maternal Immunization Enhancement Act and the Maternal Immunization Coverage Act. Members of AVAC stand ready to work with you on this, and other important and effective solutions around vaccines.

Sincerely,

AIDS Alliance for Women, Infants, Children, Youth & Families
American Immunization Registry Association
American Lung Association
American Public Health Association
Asian & Pacific Islander American Health Forum
Association of Asian Pacific Community Health Organizations (AAPCHO)
Association for Professionals in Infection Control and Epidemiology
Association of Maternal & Child Health Programs
Biondvax pharmaceuticals
Biotechnology Innovation Organization
Families Fighting Flu
GSK
Hep B United
Hepatitis B Foundation
Immunization Action Coalition
Infectious Diseases Society of America
Kimberly Coffey Foundation
March of Dimes
National Consumers League
National Foundation for Infectious Diseases
STChealth LLC
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family
WomenHeart: The National Coalition for Women with Heart Disease

AVAC Urges Senate to Support Full Funding of Immunization-Related Activities at the Department of Health and Human Services.

AVAC sent a letter to Senate members asking for $1.13 billion for immunization-related activities at the Department of Health and Human Services as part of the fiscal year (FY) 2022 Labor, Health and Human Services (LHHS), and Education Appropriations bill. This investment would strengthen the immunization infrastructure, vaccinate against COVID-19, and restore vaccination rates for routine immunizations back to pre-pandemic levels.

Letters to Congress

Appropriations/Funding for Immunization

Download

March 10, 2021

Dear Chairwoman Murray and Ranking Member Blunt,

As members of the Adult Vaccine Access Coalition (AVAC), we write to ask for full funding of immunization-related activities at the Department of Health and Human Services as part of the fiscal year (FY) 2022 Labor, Health and Human Services (LHHS), and Education Appropriations bill.

The COVID-19 pandemic has reminded us of the importance of fully funding immunization efforts. Vaccines help us mitigate diseases, prevent severe illnesses, and reduce rates of hospitalization, morbidity, and mortality. The COVID-19 pandemic has taken a catastrophic toll on our society. The rollout of safe and effective coronavirus vaccines signals a light at the end of the tunnel but there are still important steps that Congress needs to take to ensure success of the nation’s COVID-19 vaccine distribution plan. The pandemic has also introduced new challenges to our health care system that have resulted in a significant reduction in routine vaccination rates across the life course.

It is critical that the LHHS appropriations bill includes sustainable funding for immunization efforts, including long-term investments in immunization infrastructure, including immunization information systems, vaccine confidence campaigns, and support for health care providers. Immunizations are a sound investment because they are a highly cost-effective form of preventive medicine that help save lives by protecting the health and wellbeing of individuals and families in communities nationwide. Vaccines not only help protect the immunized person but they can also help protect those around them who may not be able to be immunized because they are too young to be vaccinated or suffer from a health condition that prevents them from being immunized. We ask the Committee to strongly support the following programs in the FY22 LHHS bill:

$1.13 billion for the National Immunization Program at the Centers for Disease Control and Prevention (CDC)’s National Center for Immunization and Respiratory Diseases (NCIRD) (+$400m). The immunization program at CDC provides funding to state and local health departments to carry out a variety of activities vital to the prevention, detection, and mitigation of vaccine-preventable conditions. These essential grants are utilized not only for the purchase of vaccines, but also support a number of other important infrastructure activities, including: surveillance, safety and effectiveness studies, education and outreach, implementation of evidence-based community interventions to increase immunization coverage among underserved and high-risk populations, and vaccine-preventable disease outbreak response. The resources provided under the immunization program are vital to communities across the country, many of whom rely solely on these funds to support their immunization activities.

The work of the immunization program has become even more necessary as part of the sustained COVID-19 vaccination campaign. However, COVID-19 has also exposed weaknesses in the immunization infrastructure, including a lack of adult data in the immunization information systems (IIS), vaccine hesitancy, and disparities in vaccination rates. On top of the COVID-19 pandemic, disease outbreaks – including measles, Hepatitis A, and Hepatitis B—are on the rise and investments must be made to restore vaccination rates for routine immunizations back to pre-pandemic levels.

Fortunately, most health departments already have infrastructure in place but it is imperative that Congress invest in modernizing and take steps to sustain these important investments even once the immediate threats of the pandemic. Providing $1.13 Billion in FY22 will go a long way to strengthen the immunization infrastructure, vaccinate against COVID-19, and to restore vaccination rates for routine immunizations back to pre-pandemic levels.

$241 million for Influenza Planning and Response at CDC’s NCIRD (+$40m).

CDC’s Influenza Planning and Response programs help to protect the United States from seasonal influenza and pandemic influenza. Each winter, influenza causes millions of illnesses and hundreds of thousands of hospitalizations. The 2017-2018 season was especially dangerous with an estimated 61,000 Americans having died from influenza and its complications. During the 2018-2019 season, an estimated 35.5 million people got sick with influenza and 34,200 people died. Providing $241 million for the program will ensure CDC has the resources necessary to address the continual threats posed by seasonal and pandemic influenza.

$134 million for CDC’s Division of Viral Hepatitis (+$94.5m).

In 2021, the National Viral Hepatitis Strategic Plan called for the elimination of hepatitis A, B, and C as public health threats in the United States. There is currently a large-scale outbreak of HAV, resulting in an 850% increase in cases1. HAV and HBV have a safe and highly effective vaccine that can prevent infection. Yet only 25% of adults are vaccinated for HBV, representing a lost opportunity to prevent HBV infection. Chronic HBV requires life-long medical care, as there is no cure. Providing $134 million to expand adoption of CDC/United States Preventive Services Task Force (USPSTF) recommendations for HBV and HCV testing, HBV vaccination, and linkage to care.

$10 million for the National Vaccine Program within the Office of Infectious Disease and HIV/AIDS Policy (OIDP).

The National Vaccine Program at HHS provides strategic leadership and coordination of vaccine and immunization activities among federal agencies and other stakeholders whose mandate is to help reduce the burden of preventable infectious disease. This portfolio includes the National Vaccine Plan and National Vaccine Advisory Committee. Providing a $10 Million investment will be especially important for the work this office does around vaccine equity, confidence and safety. These funds will be essential in securing future implementation of the National Vaccine Strategic Plan, a comprehensive roadmap in the development and use of vaccines across the life course in the United States.

Now more than ever, sustained and predictable, funding for the CDC immunization programs is vital, to help combat the COVID-19 pandemic, to increase routine vaccination rates and to prepare for future pandemics. We look forward to working with your office as the FY22 appropriations process gets underway. For further information, please contact the AVAC managers at info@adultvaccinesnow.org.

Sincerely,

Alliance for Aging Research
American Academy of Family Physicians
American College of Preventive Medicine
American Heart Association
American Immunization Registry Association
American Pharmacists Association
American Public Health Association
Asian & Pacific Islander American Health Forum
Association for Professionals in Infection Control and Epidemiology
Association of Asian Pacific Community Health Organizations (AAPCHO)
Association of Immunization Managers
Association of Maternal & Child Health Programs
Association of Occupational Health Nurses
Association of State and Territorial Health Officials
Biotechnology Innovation Organization
Dynavax
Families Fighting Flu
GSK
Hep B United
Hepatitis B Foundation
Hepatitis Education Project
Immunization Action Coalition
Immunization Coalition of Washington, DC
Infectious Diseases Society of America
Johnson & Johnson
March of Dimes
Medicago
Merck
Moderna
National Association of City and County Health Officials
National Association of Nutrition and Aging Services Programs (NANASP)
National Black Nurses Association
National Consumers League
National Foundation for Infectious Diseases
National Hispanic Medical Association
National Minority Quality Forum
National Viral Hepatitis Roundtable
Novavax
Pfizer
Seqirus
STC Health
Takeda Vaccines
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family
WomenHeart: The National Coalition for Women with Heart Disease

AVAC Makes Recommendations to the Biden Administration on Immunization Infrastructure Systems (IIS)

AVAC sent a letter to the White House with recommendations on how best to implement the $7.5 billion provided to immunization infrastructure through the American Rescue Plan. The letter outlined guidance from the IIS Modernization Act (H.R. 550) to help the administration meet the challenge of tracking and administering COVID-19 vaccinations.

Letters to Administration

COVID-19 Response Vaccine Infrastructure

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Dear President Biden,

The COVID-19 pandemic has taken a devastating toll on our society. With more than 400,000 American lives lost, millions of people forced to file for unemployment, and too many children falling behind in school during online instruction. As the national strategy for the efficient, effective, and equitable distribution of the COVID-19 vaccines moves forward, immunization data systems are proving to be a critical tool in the success of this effort.

We were pleased to see the American Rescue Plan Act of 2021 includes robust support for immunization infrastructure, including $7.5 billion for activities to plan, prepare for, promote, distribute, administer, monitor, and track COVID–19 vaccines. We wish to build upon the directive to provide technical assistance, guidance, and support to, and award grants or cooperative agreements to, State, local, Tribal, and territorial public health departments for enhancement of COVID–19 vaccine distribution and administration capabilities. Specifically, we wish to highlight the importance of “information technology, data, and reporting enhancements, including improvements necessary to support sharing of data related to vaccine distribution and vaccinations and systems that enhance vaccine safety, effectiveness, and uptake, particularly among underserved populations.”

While most health departments have immunization infrastructure in place, they need an infusion of support now to operationalize pandemic immunization efforts. Immunization information systems (IIS) are computerized, multi-faceted systems that operate in 62 jurisdictions, and have the ability to maintain immunization records across the lifespan. They can be used by providers to order vaccines and track inventory, view patients’ previous vaccine to ensure they are fully vaccinated but not over-vaccinated, remind patients when they are due to receive a recommended vaccine, and, at a population level, track coverage and identify areas where there are low immunization rates so public health programs can develop targeted immunization efforts in response.

We know for instance that race/ethnicity is known for just over half (55%) of people who had received at least one dose of the vaccine. Among this group, nearly two thirds were White (63%), 9% were Hispanic, 6% were Black, 5% were Asian, 2% were American Indian or Alaska Native, and <1% were Native Hawaiian or Other Pacific Islander, while nearly 14% reported multiple or other race. Under the President’s January 20th executive order to “Advance Racial Equity and Support for Underserved Communities through the Federal Government, it should not be simply enough to understand the trends when with proper investment we can pinpoint the individuals in communities of color that aren’t being served and take action to serve them.

However, IIS capabilities today vary vastly across states and many systems desperately need support to meet the challenges of a Covid-19 mass vaccination campaign, especially to track coverage and identify areas where there are low immunization rates so public health programs can develop targeted immunization efforts in response. Without investments in immunization infrastructure – IIS in particular – the racial and geographic disparities in vaccination take-up are hard to track and eradicate.

We ask that you look to the framework set out in the “IIS Modernization Act, H.R. 550” for additional guidance on how to enhance systems to manage “routine” immunization efforts and outbreaks of other vaccine preventable diseases. Among other things, the bill would authorize funding for the following activities:

An assessment of current capabilities and gaps among immunization providers;
Expand enrollment and training of immunization providers;
Support real-time immunization record data exchange and reporting;
Improve secure data collection, transmission, bidirectional exchange, maintenance, and analysis of immunization information;
Enhance security of bidirectional exchange of immunization record data and interoperability of immunization information systems with health information technology platforms; and
Enhance data exchange interoperability with other jurisdictions.

We recommend the Administration to use these funds to improve, enhance, and expand the ability of IIS to securely exchange real-time immunization record data between federal health agencies, state, local, tribal, and territorial public health programs and providers across health care settings. Again, thank you for your consideration.

Sincerely,

American Academy of Family Physicians
American Heart Association
American Lung Association
American Public Health Association
BIO
Dynavax
Families Fighting Flu
GSK
Hepatitis B Foundation/Hep B United
Immunization Action Coalition
Medicago
Merck
Moderna
National Consumers League
National Hispanic Medical Association
Sanofi
STChealth LLC
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family