Immunizations

CDC's Consolidated Comment for USCDI v4

CDC continues to recommend inclusion of this high priority data element in USCDI v4 CSTE Comment:

• CSTE agrees with CDC and continues to strongly recommends that Vaccine Administration Date and Vaccination Event Record Type be included in USCDI v4. Both elements are required for immunization exchange and always have been. Each year, IIS respond to CDC’s annual report (IISAR). At the end of calendar year 2019, IIS records contained vaccine administration date 99.9% of the time with only 1 IIS reporting less than 100%. With these lacking from USCDI v4 it would be possible to list only the immunization code a patient received, but not the date the patient received the dose or if the vaccination event originated in the source system. Vaccine Administration Date enables accurate record evaluation (e.g., were doses given at the proper age and at a proper interval) while Vaccination Event Record Type enable accurate inventory decrementing by public health and aids in vaccine matching/deduplication.

CDC's Consolidated Comment

• CDC would like to emphasize the inclusion of “Vaccination Administration Date” in USCDI v3. “Vaccination Administration Date” is the date the client received the vaccine. This is a core immunization data element used widely in the health community for a variety of purposes, such as:

1. To record the date this vaccination event occurred.
2. To document in the case of refusal or deferral, the date that the refusal or deferral was recorded.
3. In the context of a forecast dose, the date the forecast was made.
4. Many vaccines are aged-based, and vaccination administration date is used to evaluate before the vaccine is administered, whether a client is eligible to receive the specific vaccine product, has aged-out and no longer qualify for the vaccine or another vaccine product is recommended by ACIP.
5. Some vaccines belong to a vaccine series, and correct spacing between dose intervals is important for proper immunity.  Vaccine administration date is to evaluate before the vaccine is administered, whether the proper dose interval has been met or whether the series has been completed.

• Without “Vaccination Administration Date” physicians cannot determine when a patient was vaccinated, and thus:

1. Physicians cannot be assured that patients are fully vaccinated, nor can the physician inform their patient when their next vaccination is due.
2. Physicians are required to report some vaccination administrations to their jurisdictions which require “Vaccination Administration Date” for submission.
3. In the public health realm, “Vaccination Administration Date” is widely used for various purposes such population coverage information, especially in the context of social determinants of health and in vaccine effectiveness studies.
4.  “Vaccination Administration Date” is also used in immunization data quality assessments.

• Due the reasons stated above, and the importance of “Vaccination Administration Date”, it is included in thousands of Health IT related systems, such as EHRs and Immunization Information Systems. Additionally, there are harmonized standards for the implementation of “Vaccination Administration Date”.
• In summary, while vaccine type is extremely important in the medical and public health fields, “Vaccination Administration Date” is the second most important piece of information needed for accurate information. Without “Vaccination Administration Date”, base-level immunization functionality cannot occur.

CSTE Comment:

• CSTE agrees with AIRA and CDC and strongly recommends that Vaccine Administration Date and Vaccination Event Record Type be added to USCDI v3. Both elements are required for immunization exchange and always have been. Each year, IIS respond to CDC’s annual report (IISAR). At the end of calendar year 2019, IIS records contained vaccine administration date 99.9% of the time with only 1 IIS reporting less than 100%. With these lacking from USCDI v3 it would be possible to list only the immunization code a patient received, but not the date the patient received the dose or if the vaccination event originated in the source system. Vaccine Administration Date enables accurate record evaluation (e.g., were doses given at the proper age and at a proper interval) while Vaccination Event Record Type enable accurate inventory decrementing by public health and aids in vaccine matching/deduplication.

Unified Comment from CDC

• Additional Use Cases: Immunization information including date of administration is collected as part of case based surveillance for Hepatitis A, Acute Hepatitis B and Perinatal Hepatitis B to understand hepatitis transmission patterns and ensure appropriate interventions are prioritized within impacted communities.  
• Immunization elements are a major piece of public health control and mitigation. When combined with case reports to a jurisdiction or notification to CDC, it allows the jurisdiction or CDC to see where immunizations may be lacking. Immunization information may not directly provide disparity information, but it is needed together with other disparity-related data (e.g., race, ethnicity, location) to identify vaccine breakthroughs or problems with vaccination access/coverage which may also speak to broader health disparities related to general access to medical care and services.  
• Number of stakeholders who capture, access, use or exchange this data element:  All US States and DC are funded through CDC’s Division of Viral Hepatitis flagship Notice of Funding Actions to perform surveillance activities, including collection of these data for surveillance purposes.  
• Support for healthcare aims:  Improving patient experience of care, Improving health of populations, Reducing cost of care, Improving provider experience of care  
• Use of data element:  Extensively used in production environments  
• Exchange of data element: CDC Message Mapping Guides (MMG) (e.g., COVID-19) ;  
• The Multiple Chronic Conditions eCare Plan project successfully tested this element at the Sep 2020 and Jan 2021 FHIR connectathons and has implemented it at the OHSU testing site.  
• This element is used by CMS Quality Reporting and is marked Required or MustSupport in the FHIR QI Core IG  
•  CSTE supports inclusion of this measure into USCDI v3: supports information being shared with IIS across the country – should be captured for all IZ, not just children

There seems to be two data…

There seems to be two data elements in the Immunization Data Class in USCDI that are duplicates: • Vaccination Administration Date • Immunization Administered Date Is there anyway to remove one of them? We would prefer to keep Vaccination Administration Date and have the other (Immunization Administered Date, https://www.healthit.gov/isa/uscdi-data/immunization-administered-date) removed.  This field is for general comments on this specific data element. To submit new USCDI data classes and/or data elements, please use the USCDI ONDEC system: https://healthit.gov/ONDEC