October 24, 2019
Tammy R. Beckham, Director,
Office of Infectious Disease and HIV/ AIDS Policy
NVP.RFI@hhs.gov
Thank you for the opportunity to respond to your Request for Information on the 2020 National Vaccine Plan. The National Committee for Quality Assurance (NCQA) agrees that strengthening the vaccine enterprise and updating the 2010 National Vaccine Plan to account for vaccine landscape changes is a priority.
NCQA stewards of the Healthcare Effectiveness Data and Information Set (HEDIS®),[1] the most widely respected and used set of clinical quality performance measures. Our comments focus on how the 2020 plan can support the move from traditional, largely claims-based measures to measures for which we extract needed data from electronic health records, registries, health information exchanges and other electronic sources. Digital quality measures will help reduce reporting burden, improve accuracy of results and allow us to measure more of what matters from the much richer clinical data residing in electronic sources than we can find in claims. Moving to digital measures, however, requires much stronger data architecture and infrastructure that support the exchange of needed data.
1. Priorities for the 2020 National Vaccine Plan during 2020–2025. What do you recommend as the top priorities for vaccines and immunizations in the United States? Why are these priorities most important to you?
NCQA suggests two main priorities for the National Vaccine Plan.
First, the Plan should emphasize the importance of data standardization and validation as necessary steps on the path towards the effective use and sharing of immunizations information. While standards exist, most systems are not currently structured to support these standards. In addition, the Plan should prioritize the development of data architecture and a national infrastructure that promotes the ability to exchange information from immunization information systems (IIS), other data aggregators and health insurance plans back to the clinicians who need this information to provide care.
Second, the Plan should encourage ways to incentivize increased IIS reporting. As much of immunizations strategy is locally implemented through state and local public health departments, more attention should be paid to how the national strategy could support the local strategy.
2. What changes should be made to the 2010 National Vaccine Plan to make it more current and useful? This could include changes to the goals, objectives, strategies, activities, indicators, and other areas of the plan. Which components of the 2010 National Vaccine Plan worked well and should be maintained?
Goal 1 of the National Vaccine Plan includes two objectives:
- Objective 1.4. Increase the use of EHRs and IIS to collect and track adult immunization data.
- Objective 1.5. Evaluate and advance targeted quality improvement initiatives.
We advocate maintaining these objectives, as they work hand-in-hand to move the immunization enterprise towards better data systems and use of data to inform quality improvement needs. Further, the Plan could build on Objective 1.5 by encouraging the use and reporting of quality measures that focus efforts and encourage data sharing.
For example, NCQA’s Adult Immunization Status and Prenatal Immunization Status measures encourage health insurance plans to collect, aggregate and use electronic clinical data to monitor the vaccination rates among adults and pregnant women. A key feature of these measures, which use the HEDIS® Electronic Clinical Data Systems Reporting Method, is that data are standardized and accessible to the care teams providing services — a necessary element of effective clinical decision support.
3. What are the goals, objectives, and strategies for each of your top priority areas? Are there any goals in the current strategy that should be discarded or revised? Which ones and why?
Objectives could include promoting the development of a sustainable infrastructure by supporting standards and validation of the data. Learnings from implementation of the HITECH Act can be applied to immunizations plans to promote a standardized approach that encourages the push/pull of data.
4. What indicators can be used to measure your top priorities and goals? Are there any indicators in the 2010 National Vaccine Plan or the National Adult Immunization Plan (https:// www.hhs.gov/sites/default/files/nvpo/ national-adult-immunization-plan/ naip.pdf) that should continue to be used? If so, which ones, and why?
States should continue to monitor immunization coverage rates as an overall way to understand coverage. However, indicators that provide an understanding of health system performance towards better data flow would be useful. For example, are providers participating in partnerships to discuss data flow? How many adults are covered in IIS?
5. Identify which stakeholders you believe should have responsibility for enacting the objectives and strategies listed in the 2020 National Vaccine Plan, as well as for any new objectives and strategies you suggest. Specifically identify roles that you or your organization might have in the 2020 National Vaccine Plan.
States and localities responsible for public health functions have a key role in encouraging standardization and increased participation in data sharing. While providers have a responsibility for submitting vaccination data, if the systems are not poised to accept and transfer the data in a standardized fashion, collection of information falls short.
Thank you again for the opportunity to comment on the request. If you have questions please contact Paul Cotton, Director of Federal Affairs, at (202) 955-5162 or cotton@ncqa.org.
Sincerely,
Michael Barr, MD
Executive Vice President
[1] HEDIS is a registered trademark of NCQA.