Enhancing Participation in Immunization Information Systems (IIS): Recommendations to the National Vaccine Advisory Committee

A meeting on Enhancing Participation in Immunization Information Systems (IIS) was held February 7-8, 2008, at the U.S. Department of Health and Human Services (DHHS), Hubert H. Humphrey Building in Washington, DC. The meeting was sponsored by the DHHS National Vaccine Program Office (NVPO) and the National Vaccine Advisory Committee (NVAC). NVPO and NVAC organized the meeting in collaboration with the American Immunization Registry Association (AIRA), Every Child By Two (ECBT), the Association of Immunization Managers (AIM), and the Office of the National Coordinator (ONC) for Health Information Technology in DHHS. The meeting was in follow-up to recommendations from NVAC in its recent report, Immunization Information Systems: NVAC Progress Report. In this report, NVAC recommended that NVPO and NVAC convene a meeting of representatives of state and local health departments, health insurers, health plans, the Centers for Medicare and Medicaid Services (CMS), health care professional organizations, and others to address some of the challenges for IIS, in particular to:

• deliberate the pros and cons of provider performance incentives based on the completeness of immunization data available in an IIS
• deliberate the pros and cons of legislative and other approaches to increase provider participation in an IIS
• develop a statement noting the value of IIS and urging financial support for IIS.

Sixty-three persons participated in the meeting.

Conclusions and Recommendations from the meeting to the NVAC were:

Policy/Regulatory Approaches

• IIS participation is a public health imperative. All people and all providers should participate.
• Immunizations should be reportable events across the lifespan. Records in IIS should be stored in perpetuity.
• Access to IIS information should be available to community partners (e.g., schools, Women Infant Children [WIC] programs, daycare settings) and health plans. To support IIS interstate data sharing:
  • Explore the feasibility of using the National Association for Public Health Statistics and Information Systems (NAPHSIS) interstate transfer standard agreement model for IIS interstate data exchange for both IIS and individual providers.
  • Explore the feasibility of federal legislation similar to that covering cancer registry reporting to allow state-to-state data exchange for IIS and providers
  • Until national solutions can be developed, states should consider passing legislation which ensures the timely, secure interstate exchange of immunization information. One example of a model statute exists at http://www.ecbt.org/registries/modelinterstate.cfm.
• Assure IIS are interoperable with electronic health record (EHR) systems
• Reinterpret the Family Educational Rights and Privacy Act to remove barriers to sharing information between schools and IIS.

Provider Incentives

Four broad categories of provider incentives were identified to increase participation in IIS:

• Monetary - possible approaches are:
  • Provide periodic rewards for achievement (e.g., for each fully immunized child documented in IIS).
  • Include the cost of entering the data into the registry in the reimbursement for administering vaccine.
  • Work with the Centers for Medicare and Medicaid Services (CMS) and state Medicaid directors to increase state Medicaid reimbursement for vaccine administration to the maximum allowable level.
• Workflow Efficiency/Medical Decision Making
  • Provide technical support to medical offices to integrate IIS use into office work patterns
  • Use IIS forecasting ability to replace having to look up complicated immunization schedules.
  • Include vaccine inventory management in IIS
  • IIS should be integrated with other preventive health services information systems
  • Remove legal and policy barriers to allow bi-directional sharing of data between schools and other appropriate stakeholders.
• Education
  • Quality Improvement:
    • Feed data being collected currently back to physicians to show them the value of participating in the registry.
    • Develop continuing education materials on the use of IIS (working with manufacturers/vendors/specialty professional organizations).
  • Incorporate IIS topics in certification and re-certification processes.
• Technology
  • Provide real-time exchange of information with medical providers.
  • Assure IIS allow bulk data import and return data to medical providers (bi-directional) using HL7 format by 2010
  • Promote common standards usage with HL7 format.

Financial Support

• A dedicated sustainable permanent federal funding source for Immunization Information Systems is essential. At the present time, there are two vehicles for doing that, VFC operational funding and the 317 program. VFC and 317 programmatic funds should be increased to provide more support.
• Assure other federal funding programs that support activities that relate to IIS (e.g., WIC, pandemic influenza, bio-preparedness) are more than just permissive. These programs should encourage the use of their funding to support the IIS infrastructure.
• Explore other potential sources, such as
  • federal funding for health information technology initiatives in which registries are an important component
  • new per-dose excise tax on vaccines

September 2008