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AAFP to Feds on Vaccines: End EHR Costs, Fight Hesitancy

October 29, 2019 02:32 pm News Staff – Every American should be appropriately immunized, the Academy reminded federal regulators in a recent letter, but electronic recordkeeping needs a shot of its own to prevent physicians and their patients from being gouged by the process.

Reducing physicians' administrative burdens associated with vaccine administration "should be a priority," the AAFP told Tammy Beckham, D.V.M., Ph.D., director of HHS' Office of Infectious Disease and HIV/AIDS Policy, in an Oct. 24 letter addressing the agency's 2020 National Vaccine Plan.

The correspondence, signed by Board Chair John Cullen, M.D., of Valdez, Alaska, singled out a particular -- and often costly -- vexation among physicians working toward disease prevention: Federal policy, the Academy wrote, should ensure that EHR vendors "do not create a financial burden on their customers on needed immunization functionality."

doctor in white coat making injection to senior patient in clinic

Today, such companies charge high rates to connect physicians to state immunization registries that are not standardized and not nationally interoperable. The upcoming federal plan, the Academy said, "should relieve physicians and users of EHRs of the burden of enabling data exchange with immunization registries."

"HHS must hold vendors of EHR systems and immunization registries accountable for this function with ability to enable automatic feeds to registries with no burden imposed on users of systems," the letter added. "HHS must hold information technology vendors accountable for creating a national standardized, easily accessible, accurate, robust immunization information system."

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In such a system, every administrator of vaccines should be compelled to report standard information to the appropriate state or national registry, the AAFP said. And HHS should require all public and private payers "to share claims data with patients and physicians and contribute to immunization databases to help track longitudinal immunization history."

More broadly, the Academy restated its longstanding call to immunize all children and adults, regardless of their economic or insurance status, and said that public and private insurers should cover all AAFP-recommended immunizations without copayments or deductibles, regardless of network status or plan.

"No insurance plan should be exempt from covering immunizations," the letter said. "Prices should be standardized nationwide for all vaccines.

"Where medical practices incur a cost for vaccines, the AAFP calls for adequate payment for the vaccine itself and all associated overhead costs (i.e., acquisition, storage, inventory, insurance, spoilage/wastage, etc.) of all immunizations recommended by the AAFP, and their administration, with no patient cost-sharing, as well as covering an evaluation and management service during the same visit, when a significant and separately identifiable E/M service is provided and documented."

The Academy was responding to a request for information to help in developing the plan that HHS published in the Sept. 24 Federal Register.

The AAFP's comments about the 2020 NVP -- which Congress mandates to ensure an adequate supply of vaccines and access to them -- also outlined priorities meant to push back against vaccine hesitancy and address related public health concerns.

"The nation must combat vaccine hesitancy by executing a broad and persistent social marketing campaign countering misinformation leading to increases in vaccine hesitancy," the letter said. "In addition, HHS must counter the rise in nonmedical exemptions for vaccines by funding certain federal health programs contingent on removal of nonmedical vaccine exemptions."

The Academy also said that Vaccine Information Statements and other patient communications must be simplified and quicker to read, with language that patients can understand.

To gauge the success of such efforts, the Academy suggested that public and private payers use geo-mapping to track vaccination rates by ZIP code and target improvements where needed.

"HHS should track exemptions and reasons for not being vaccinated," the letter said.

"A priority for the 2020 plan must be to bridge the gap in getting immunizations to rural America," the Academy stated. "Increases in children's, adolescents' and adults' immunization rates in rural areas, as well as urban ones, are the best protection against preventable diseases."