On March 4, the AAFP sent letters to the CDC and HHS responding to the agencies' calls for comment on the CDC's revised Vaccine Information Statements(www.gpo.gov) for multiple pediatric vaccines and HHS' draft National Adult Immunization Plan.(www.hhs.gov)
Both letters referenced the Academy's immunization policy, which lays out the AAFP's continued support for vaccination promotion.
Pediatric Vaccine Information Statements
The letter to the CDC(2 page PDF) opens by noting that under the authority of the National Childhood Vaccine Injury Act, the CDC "develops vaccine information materials that all health care providers are required to give to patients/parents prior to administration of specific vaccines."
"It is AAFP policy to endorse the concept that all children and adults, regardless of economic and insurance status, should have access to all necessary immunizations," the letter states. "The AAFP believes that all public and private insurers should include, as a covered benefit, all necessary immunizations without co-payments or deductibles."
- On March 4, the AAFP sent letters to the CDC and HHS responding to the agencies' calls for comment on updated immunization information.
- The letter to the CDC explains that it is AAFP policy to "endorse the concept that all children and adults, regardless of economic and insurance status, should have access to all necessary immunizations."
- Both letters point to the burden posed by the Vaccines for Children (VFC) program's requirement that VFC vaccines be stocked separately from those covered by other payers.
In addition, the letter outlines the Academy's stance that vaccine manufacturers and distributors should offer payment policies that minimize the financial risk associated with physicians maintaining a vaccine inventory. To that end, says the AAFP, the Vaccines for Children (VFC) program, immunization grants authorized under Section 317 of the Public Health Service Act and state "universal purchasing" initiatives that subsidize vaccines at no cost to medical practices should be adequately funded by federal and state governments.
To cover all the costs a practice incurs for vaccines, adequate payment should include costs for the vaccine itself and the associated overhead of acquiring, storing, insuring and accounting for vaccine spoilage and waste, the AAFP letter notes, with no cost-sharing by patients. The letter also recommends that states allow physicians to store VFC vaccines intermingled with other vaccine supplies with appropriate documentation and cost accounting.
The letter concludes by saying that scientifically accurate vaccine information materials are important "in facilitating an informed discussion between the clinician and caregiver of the child receiving the vaccine."
"The AAFP strongly supports the development and appropriate revisions of these materials and is pleased to continue its partnership with the CDC and American Academy of Pediatrics in developing and updating the Provider Resources for Vaccine Conversations with Parents(www.cdc.gov) resources."
All comments on this issue are due to the CDC by March 10.
National Adult Immunization Plan
The letter to HHS(5 page PDF) about the agency's proposed plan to boost adult immunizations nationwide begins by saying that the AAFP concurs with the agency's contention that adult vaccination rates remain low in the United States and that significant racial and ethnic disparities exist.
"We agree with the strategic goal of improving adult immunizations and that vaccination is one the most important public health achievements that saves lives and improves the quality of life by reducing the transmission of infectious diseases," the letter reads.
Like the CDC letter, this document also points to the burden posed by the VFC program's requirement that VFC vaccines be stored separately from those covered by other payers and repeats the AAFP's suggestion to allow intermingling of the two vaccine supplies.
In addition, the letter notes that although the advent of immunizations being offered outside the medical home has improved patients' access to vaccines, the Academy would support policies to require that immunization information be communicated back to the patient's medical home.
The Academy's letter also endorses the idea of vaccine manufacturers developing contingency plans for appropriately timing and prioritizing vaccine supplies if an adequate supply is delayed or reduced.
The letter concludes by outlining the AAFP's stance that adoption of standardized transport by Immunization Information Systems (IIS) and electronic health record systems needs to increase to allow for a consistent exchange of information inside the health care system. Recognizing that IIS are not available in all states, the Academy urged HHS to promote their use across the country.
The comment period on this issue has been extended(www.gpo.gov) to March 23.
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