The Affordable Care Act (ACA) requirement that private payers cover all vaccines recommended by the Centers for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization (ACIP) is due to the Inflation Reduction Act. now applies to Medicaid and Medicare Part D.that 9 out of 10 Americans cover vaccines without sharing costsThe Centers for Medicare and Medicaid Services (CMS) have taken great care to emphasize that Part D plans must cover travel vaccines, but they do not offer equal coverage to private insurance and Medicaid beneficiaries. Further clarification is needed to provide access. this is, previous analysis It turns out that the majority of Americans with private insurance do not have health insurance, including travel vaccines.
Compensation without cost-sharing (the first $1 of compensation) is a particularly important tool for ensuring access to vaccines. By eliminating unnecessary services and utilization management tools such as patient cost sharing, potential overuse of health services can be reduced to desired levels. However, clinical preventive services aimed at preventing the spread of disease, protecting public health, and saving healthcare costs should probably be encouraged.Out-of-pocket expenses of any amount may discourage patients From choosing to receive the vaccine. Furthermore, it is well established that clarity of vaccine recommendations and coverage and out-of-pocket costs are all essential for provider recommendations and patient acceptance of vaccines.
The ACA’s vaccination requirements do not distinguish between travel vaccines and other vaccines.under Rules of practice for CMS, the ACA is interpreted to require immunization coverage recommended by the ACIP for “regular use.” clarifies that it means “as set forth in So if the CDC places a vaccine on its immunization schedule, it should be covered.
CDC Travel Vaccine Recommendation “Grey Zone”
CDC regularly and diligently review The structure, content, design and even color scheme of an immunization schedule with ACIP during a public meeting. However, it is unclear from the schedule whether vaccines for travel are included. In that note, the schedule indicates that some vaccines (e.g., hepatitis A, hepatitis B, measles, mumps, rubella, meningococcal, and polio) are recommended for international travelers. , schedule notes are separate from that table and are not included. A comprehensive list of all vaccines recommended for travel, omitting vaccines recommended for specific destinations. That information is stored elsewhere on the CDC’s website, creating a maze for travelers, urging them to book vaccines for which coverage may not exist, while travel vaccines are covered. It does not provide clarity of coverage.
of Immunization schedule landing page We provide a list of “Adult Immunization Schedule Vaccines” omitting recommended travel vaccines. According to the CDC “Travel vaccine” page, travelers should ensure they are up to date on all “routine vaccines” and mention the measles vaccine. It then directs travelers to a series of pages describing recommended vaccines for specific destinations, and then offers to book the appropriate travel vaccines.another The link to “Travel Vaccine Recommendations” leads to the “Traveler Health” page. Again, it emphasizes the importance of “routine vaccinations” and provides a variety of other traveler health information. Yet Another CDC Page The table entitled “Disease-Specific Vaccines” lists “Vaccines Recommended for Travel and Some Specific Groups”, including adenovirus, anthrax, cholera, Japanese encephalitis (JE), rabies, smallpox, tuberculosis, typhoid, and yellow fever.
Each of the above vaccines was recommended by ACIP to address specific risks to travelers based on a review of available evidence. Ensuring that these recommendations are expressed in the form of a health coverage policy will help facilitate rather than hinder access. In essence, these recommendations are not broad enough to encourage unnecessary use and cost. But to assume that those coverages should be excluded defeats the purpose of recommending vaccines aimed at reducing risk to travelers and preventing the disease from crossing borders.
CDC vaccination schedules should clearly delineate travel vaccine recommendations
There are two simple, legally supported ways for the CDC to clarify that travel vaccine coverage is required under the ACA.
CDC only needs to issue guidance clarifying that travel vaccines are in fact “on schedule” and therefore must be covered under the ACA. This is not unprecedented.When he explained in 2019 that the ACIP’s “shared clinical decision-making” recommendations were too vague and confusing for providers and payers, the CDC Published a series of FAQs “This coverage requirement includes shared clinical decision-making recommendations when adopted by CDC and included in immunization schedules.” Similar guidance from CDC states that travel lists can be specified as part of the schedule itself and subject to coverage requirements.
CDC will also integrate the above list of recommended travel vaccines into its immunization schedule, creating a table of recommended vaccines, as well as other regularly recommended vaccines, which can trigger an “on schedule” requirement. There is a possibility
CMS may also provide clarity and consistency in travel vaccine coverage
among them Recent Guidance for Part D Sponsors To implement the IRA’s new zero-cost sharing policy on vaccines, CMS states that the ACIP recommendations include “Limitations on certain other vaccines not included in the CDC/ACIP adult immunization schedule for routine immunization. “for use in designated populations and situations.” [including] Limited population and situation. This language is readily adopted by CMS and provides important and necessary clarity on travel vaccine coverage that may apply to private health plans and Medicaid under the ACA.
Failure to clarify travel vaccine eligibility requirements could result in specialization and semantics beyond the meaning of a “schedule” that would undermine the millions of U.S. travelers who each year receive potentially life-saving vaccines. It can get in the way. Both CDC and CMS have the mandate to provide this necessary clarity through simple, clear guidance.
author’s note
The authors regularly advise clients, including vaccine manufacturers, on policy, legal, and regulatory issues.
