October 2007 NVAC Meeting Minutes
The part D vaccination program is implemented by independent plans operating in different regions with different formularies. In 2008, all commercially available vaccines, other than those offered under the part B vaccination program, will be required on all formularies. Another change is that, in 2007, there was a bridge law, which separated the ingredient payment under part D from the administration payment under part B; however, next year both payments will be under part D.
Dr. Kelman spoke about three reimbursement approaches in use: The in-network approach, the out-of-network approach, and the hybrid—or combined—approach. All three approaches worked during 2007, and CMS expects the same for 2008.
Dr. Kelman also discussed the Medicare Advantage Plan. Nine million of the 43 million people who have Medicare are taken care of through the Medicare Advantage Plan. The Medicare Advantage Plan has the same requirement about vaccinations and basically offers the same benefits.
Dr. Kelman concluded his presentation by mentioning part D data elements. With a new data regulation, CMS hopes to have data on the use of part D vaccines by State.
Dr. Freed began the discussion by asking who bills Medicare when a specialty or retail pharmacy sends vaccine to a provider in bulk. Dr. Kelman explained that the specialty or retail pharmacy bills Medicare directly but that the dose is billed to the plan at the point of administration.
Dr. Pavia mentioned that one of the barriers to adult immunization is complexity in reimbursement. He asked if CMS had any data from providers about the time involved, the barriers to, or the acceptance of part D regulations. Dr. Kelman explained that part D is new and that CMS is still trying to analyze data from 2006. According to one study, beneficiary satisfaction with the program was at 80 percent as the program is not as complex for the beneficiary as it may be for the provider. Dr. Kelman agreed that there was more paperwork with this program but that CMS is trying to reduce this burden. He also mentioned that the program came in well under budget.
Dr. Feinberg asked if CMS conducted detailed analysis on how satisfied providers and patients really are with the part D program as he found the statistic of 80 percent hard to believe. He was curious as to how many people were experiencing difficulties and not receiving vaccines because of barriers. Dr. Kelman explained that CMS would be willing to change its policies if it meant eliminating barriers. He went on to say that the survey indicating an 80-percent satisfaction level was done by an outside organization and that followup surveys are done each year to look at satisfaction from the consumer point of view.
Dr. Guthrie S. Birkhead expressed concern about the program coming in under budget as it suggests underutilization of the program. He wondered if the recommendation should be made for NVAC to measure vaccine coverage by insurance status and by plan type within the Medicare program. He expressed concern that the vaccines were not getting to those who needed them. Dr. Kelman stated that the program came in under budget due to better pricing and not due to complexity issues or underutilization of the program.
Dr. Jon R. Almquist asked what percentage of adults who qualify for Medicare elected to have a pharmaceutical plan. Dr. Kelman explained that in 2005, 40 percent of seniors had no drug coverage; however, this year less than 7 percent were without drug coverage.
Vaccination Coverage Among Adults—Mr. James A. Singleton