Updated National Vaccine Plan: How well does it address IIS issues?

On November 23, 2020, the Centers for Disease Control and Prevention (CDC) Office of Infectious Disease and HIV/AIDS Policy (OIDP) published a draft Vaccines National Strategic Plan 2021-2025. This is an update of the National Vaccine Plan last published in 2010. This updated draft vaccine plan provides a vision for the nation’s vaccine and immunization enterprise for the next five years and articulates a comprehensive strategy to enhance vaccination in the United States.

So how well does this draft plan address the concerns of public health and Immunization Information Systems (IIS)? Overall, IIS certainly do find their place. Objective 4.3 affirms the need to “Strengthen data infrastructure, including Immunization Information Systems, to track vaccine coverage in the United States and conduct surveillance of vaccine-preventable diseases.” Objective 5.3 recognizes the need to “Support global partners to strengthen immunization systems,” though the related strategies extend beyond information systems to systems more broadly.

But there are a few small gaps. In the opening section on progress since the last plan in 2010, when discussing vaccine safety and the Vaccine Adverse Event Reporting System (VAERS), the plan makes reference to, “…transitioning vaccine manufacturers to reporting using standardized messages through electronic data exchange.” It seems to me that CDC should also address the needs of adverse event reporters: To date there is still no application programming interface (API) to VAERS which would enable system-to-system transmission of a VAERS report between, say, an Electronic Health Record (EHR) or an IIS and CDC. Strategy 2.2.1 within the plan (“Strengthen integration of systems that track vaccine administration and adverse events associated with vaccines”) could certainly address this. And with a COVID-19 vaccine on the horizon the need to automate VAERS reporting will become more acute.

Another part of the opening sections addresses the role of pharmacists in immunization as an example of a “non-traditional setting” that has been leveraged to improve access to immunizations. The US Department of Health and Human Services (HHS) recently expanded the ability of licensed pharmacists to administer routine childhood vaccines during the pandemic. But this move was not without controversy: the American Academy of Pediatrics (AAP) continues to believe this step was unwise as it removes immunization from the hands of pediatricians better able to deal with issues of parent education, vaccine hesitancy, and more complex childhood medical conditions.  There is no other reference to pharmacists in the base of the plan (other than a reference to pharmacy education), so perhaps CDC was striking a balance by recognizing the impact of pharmacies without really advocating specifically for an expansion of their role in childhood immunization.

Finally, the plan could be more accurate about the limitations of inter-jurisdictional sharing of immunization information especially between IIS. The plan says that, “…state and local immunization programs do not have the legal authority to share individual vaccination data across state jurisdictions….” It would be more accurate to say that they do not consistently share information as some jurisdictions are well within their legal ability to do so and some do in fact support this function. The American Immunization Registry Association (AIRA) coordinates the signing of an inter-jurisdictional memorandum of understanding that provides a common policy framework for those jurisdictions which choose to participate.

All comments must be received by CDC by 5:00 p.m. ET on December 3, 2020 to be considered.