RE: Hospital Inpatient and Outpatient Process and Structural Measure Development and Maintenance (Hospital-MDM). Contract number HHSM-500-2013-13011I

As participants in the Adult Vaccine Access Coalition (AVAC), we appreciate the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) effort to develop an electronic clinical quality measure (eCQMs) for influenza immunization for use by providers in CMS quality reporting programs.

AVAC consists of 45 organizational leaders in health and public health that are committed to tackling the range of barriers to adult immunization and to raising awareness of the importance of adult immunization. AVAC works towards common legislative and regulatory solutions that will strengthen and enhance access to adult immunization across the health care system. Our mission is informed by a growing body of scientific and empirical evidence in support of the benefits immunizations provide by improving health, protecting lives against a variety of debilitating and potentially deadly conditions and saving costs to the healthcare system and to society as a whole.

AVAC priorities and objectives are driven by a consensus process with the goal of enabling the range of stakeholders to have a voice in the effort to improve access and utilization of adult immunizations. One of our key coalition priorities is to support the strengthening and establishment of additional federal benchmarks and quality measures around adult immunizations. More comprehensive tracking and reporting of process and outcome measures will reduce the number of missed immunization opportunities and is imperative to improving health and reducing the burden of vaccine preventable disease.

Immunization quality measures are a crucial tool for health care quality improvement and have demonstrated effectiveness in increasing immunization rates. Monitoring and reporting of offered and administered immunizations helps to ensure that the range of available immunizations remain a priority and in the forefront of clinical care standards. The Advisory Committee on Immunization Practices (ACIP) recommends seasonal influenza vaccination for all persons 6 months of age and older. According to the 2014 National Health Information Survey, 72 percent of individuals age 65 and over received the flu vaccine. However, these rates fall short of the Healthy People 2020 goal of 90 percent.

Influenza vaccination is the most effective method for preventing influenza virus infection and its potentially severe health consequences. Medicare beneficiaries are at particularly high risk of suffering from complications associated with the influenza virus. AVAC supports the inclusion of IMM-2, for acute care hospitalized inpatients age 6 months or older in the Hospital VBP Program. Influenza causes approximately 200,000 hospitalizations and 36,000 deaths in the United States annually. Immunization is “effective prevention” in reducing rates of morbidity and mortality from a growing number of preventable conditions and has been demonstrated to improve overall health in a cost efficient manner.

Quality measures such as IMM-2 help drive immunization rates by ensuring healthcare providers offer recommended vaccines to their patients, reducing the number of missed opportunities to vaccinate patients and increasing vaccination rates. As the adoption of electronic health records (EHRs) among health care providers grows, the vast majority of systems include capability to track immunization status.

AVAC commends CMS for proposing to include IMM-2 as an eQM for use in CMS quality programs such as the Hospital Value-Based purchasing program and encourage the agency to work with the Office of the National Coordinator and other federal and outside stakeholder groups to ensure seamless and accurate reporting of immunization status and quality reporting measures through a provider EHR.

Thank you for the opportunity to offer our perspective. Please contact the AVAC Coalition Manager (202) 540-1070 or info@adultvaccinesnow.org if you wish to discuss our comments or adult immunization issues.

American Association of Occupational Health Nurses (AAOHN)
American College of Preventive Medicine (ACPM)
Asian & Pacific Islander American Health Forum (APIAHF)
MedImmune
National Association of City and County Health Officials (NACCHO)
National Black Nurses Association (NBNA)
Sanofi
Takeda Pharmaceuticals
The Gerontological Society of America
Trust for America’s Health
Hep B United
Hepatitis B Foundation