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  • ACOEM Comments to NQF on Adult Immunizations

     Submitted Electronically to the National Quality Forum — July 14, 2014 

    The American College of Occupational and Environmental Medicine (ACOEM) applauds the inclusion of Adult Immunization Measures in the NQF effort to define gaps in quality and efficiency measures and to develop multistakeholder recommendations for future measure development and endorsement. We believe that employers have a major stake in the outcomes of adult immunizations, one which we in ACOEM do not believe was fully recognized in the draft report. We believe an employer representative should be specifically represented on the NQF Adult Immunizations Committee.

    Employers have a vested interest in the health of the population as it directly impacts their economic outcomes. Employers bear a substantial burden as a result of worker ill-health in terms of direct (health care costs) and indirect (cost of absence, replacement workers, lost productivity etc.) costs.

    Employers have significant influence over process elements that drive adult immunization rates. Employers can influence the health care benefit design they purchase and often contract with vendors to provide adult immunizations to augment the success rates, especially for but not limited to annual influenza immunization. Employers are frequently the locus for delivery of adult immunizations through travel health programs, on-site or near-site employee health clinics, employee health fairs or other vaccine-promotion programs such as voucher programs for remote employees. Finally, employers can serve as an important communication channel for important health initiatives.

    The role of employers in enabling health should not be underestimated. Employers will bear a productivity impact of ill-health but can also influence health through communication channels and other positive social determinants of health.

    We endorse the report’s acknowledgement of the challenges imposed by disparate data sources for adult immunizations and the recommendation for national immunization registries.

    Health care providers should be evaluated on their process and outcomes performances on these actions: establishing a behavioral norm of collecting adult immunization history at least once a year; periodically taking and updating a complete immunization history for all adult patients; coordinating the provision to their adult patients any and all appropriate immunizations; entering any and all immunizations delivered into the appropriate immunization registry; state registries should include patient opt-out clauses for dissemination of information to all involved in administering vaccinations with access to registries by all involved with administering vaccines; advocating for and implementing (where available) adult immunization data integration between and among practice/clinic information systems, hospital information systems, community immunization registries, other provider information systems.