America's Health Insurance Plans supports the need for the entire population to have access to the COVID-19 vaccine and acknowledges that federal law requires most health insurers to cover vaccines recommended by the Advisory Committee on Immunization Practices without a cost-share for consumers.
However, AHIP said as the vaccine becomes more widely available and potentially delivered through doctors' offices and pharmacies across the country, providers may charge an administration fee to cover some associated costs.
"Society must balance the public health imperative of administering the vaccine to everyone while ensuring affordability," AHIP said. "Drug manufacturers must offer their vaccine(s) at an affordable price."
AHIP made its comments to "A Framework for Equitable Allocation of Vaccine for the Novel Coronavirus," released by the National Academies of Sciences, Engineering, and Medicine.
"The Framework indicates that, 'In the national interest, Medicare and Medicaid should require free vaccine administration; providers should not charge private plans or consumers; and private insurers and employers should not charge co-pays or deductibles for vaccine administration,'" AHIP said. "It is important to note that there will likely be substantial costs associated with the significant cold chain (freezing) requirements expected for some of the vaccines as well as the supplies needed to provide the vaccine. This may require centralized distribution centers, at least initially."
When a vaccine becomes available, there will initially be limited supply, AHIP said.
"Therefore, there must be a plan to phase the allocation of COVID vaccines over time as the supply increases until they are widely available for the entire population."
Insurers can use their member data to help identify which people meet the criteria to be eligible for the vaccine, according to the best available evidence. Outreach efforts must adhere to patient privacy requirements, AHIP said.
Insurers can coordinate across partners such as public health officials for data sharing regarding their members' vaccine status, encouraging data to be shared with state or regional databases (Immunization Information Systems).
"Health insurance providers play an important role ensuring that people receive the vaccines that are recommended for them, and have experience conducting outreach to their members to inform them of the vaccines that are recommended for them and how they can get them," AHIP said. This may include reminders to ensure they receive multiple doses of a vaccine when needed."
Following the release of a vaccine for COVID-19, some insurance providers could play a collaborative role in the post-market safety surveillance system by contributing real-world data on the safety and efficacy of such a vaccine to the Food and Drug Administration (FDA), the Centers for Disease Control and Prevention (CDC) and other authorities.
AHIP sent comments to Committee Co-chairs William H. Foege, MD, and Helene D. Gayle, MD.
WHY THIS MATTERS
There are many uncertainties about when a vaccine will be approved, what the evidence will say about the populations it will be safest and most effective for; the requirements for shipping, storage, and administration; how the vaccine will be distributed; and the public's perception about the vaccine, AHIP said.
"There has been significant federal government investment to accelerate the development of vaccines," AHIP said. "However, no matter how many of the vaccine candidates are ultimately successful, there will be a limited supply of the vaccine available initially."
THE LARGER TREND
Phase I for the vaccine should include healthcare professionals who regularly interact with patients, including non-licensed staff such as those involved in transportation and housekeeping.
AHIP recommends the committee provide additional guidance on how to prioritize populations within each of the phases.
"There will be a limited supply of vaccine available initially," AHIP said in the letter. "The size of the population in each of the phases outlined by the Committee is quite large and ultimately the entire population will need to have access to the vaccine."
For example, Phase 2 includes 30% to 35% of the U.S. population, over 100 million people. It will likely take some time before the supply of the vaccine will be available to meet the needs of the populations included in Phase 2, let alone Phases 3 and 4, AHIP said.
ON THE RECORD
"We recognize the many challenges associated with allocating the vaccine, including considerations of the needs of vulnerable and diverse ethnic communities, along with the urgency to deliver the vaccine to front-line health care personnel caring for patients and essential workers to support reopening of the economy," said Matthew Eyles, AHIP president and CEO.
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