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Vaccines for Children (VFC) Compliance and Vaccine Storage & Handling
Training, Webinar 2020
Rattana Bip, Vaccines for Children Coordinator
Massachusetts Department of Public Health | Immunization DivisionVaccine Management UnitEmail: [email protected]: 617-983-6828 | F: 617-983-6924
Presenter Disclosure• I, Rattana Bip, have been asked to disclose any
significant relationships with commercial entities that are either providing financial support for this program or whose products or services are mentioned during my presentations.
• I have no relationships to disclose.• I may discuss the use of vaccines in a manner not
approved by the U.S. Food and Drug Administration but in accordance with ACIP recommendations.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Agenda• Overview of the Vaccines for Children Program• Vaccine Availability• Guidelines for Compliance
▫ Appropriate use of State-Supplied Vaccine▫ Vaccine Management▫ Billing and Charging for State-Supplied Vaccines▫ Vaccine Information Statements (VIS) and Consent
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccines for Children (VFC) ProgramThe Vaccines for Children (VFC) program was established by Congress in 1994 to increase access to vaccination for children who might not get vaccinated due to financial barriers.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
VFC EligibilityThe VFC program serves children through 18 years of age who meet at least one of the following criteria
• Enrolled in Medicaid• Uninsured• Under-insured and seen at an FQHC• American Indian (Native American) or Alaska Native
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
State-Supplied Vaccines AvailabilityMassachusetts universally supplies all routinely recommended pediatric vaccines to any child through 18 years of age regardless of insurance status. Those children not covered by the federal VFC Program are covered by a state trust fund. • Massachusetts also supplies no cost vaccines to
uninsured adults seen at public provider sites (CHCs, BOHs).
• All state-supplied vaccines can be used only according to the Childhood and Adult Vaccine Availability Tables.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Guidelines for Compliance• Vaccine management and VFC requirements
and recommendations are detailed in the ‘Guidelines for Compliance with Federal and State Vaccine Administration Requirements’https://www.mass.gov/resource/vaccine-management.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
APPROPRIATE USE OF STATE-SUPPLIED VACCINE
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Availability TablesProviders must use state-supplied vaccines only for children and adults determined eligible as defined in the most recent versions of the ‘Childhood Vaccine Availability Table’ and the ‘Adult Vaccine Availability Table’. The vaccine availability table can be found here: https://www.mass.gov/resource/vaccine-management
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
VFC Screening• Providers must screen all children (birth through 18 years of
age) at every immunization visit.• Patient eligibility screening for VFC may be recorded
electronically if all information requested in the VFC Patient Eligibility Screening Form is both recorded and retrievable in the event of a VFC site visit.
• VFC screening information must be retained in the electronic medical record or on file in the office for a minimum of 3 years after service to the patient has been completed.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Borrowing VaccinesBorrowing vaccine is defined as the use of a dose of state-supplied vaccine for a child not eligible for state-supplied vaccine when privately purchased vaccine is not readily available or vice versa. • Borrowing vaccine should be extremely rare and only occur to
avoid a missed opportunity to provide a needed vaccine for a child who might otherwise not receive vaccine.
• State-supplied vaccine may never be borrowed for use in someone 19 years of age or older.
• If a provider borrows state-supplied vaccine, a Vaccine Borrowing Report Form must be completed and fax to the Vaccine Management Unit.▫ Borrowing reports must be kept on file and available for review during a
site visit.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Fraud and AbuseImproper use of state-supplied vaccine may constitute fraud and abuse.• Fraud – intentional deception made by a person with the
knowledge that it could result in some unauthorized benefit to themselves or some other person.
• Abuse – provider practices that are inconsistent with sound fiscal, business, or medical practices, and result in unnecessary cost to the Medicaid program, Immunization Division, Health Insurance Company, or patient.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Example of Fraud and AbuseFraud and abuse can include (but is not limited to):• Selling or misdirecting state-supplied vaccine.• Billing a patient or third party for state-supplied
vaccine.• Charging more than the administration fee for state-
supplied vaccine.• Failing to account for state-supplied vaccine.• Failing to receive, store, or use vaccine.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
RestitutionMDPH will require providers to make restitution for any doses of state-supplied vaccines that have been lost due to the provider’s failure to properly receive, store, or use vaccines if:• 1st incident and the total loss is over $10,000• 2nd incident (or greater) regardless of total value • Due to a failure to immediately open a vaccine shipment from
McKesson or Merck resulting in damaged vaccine regardless of total value
• Due to a failure to store refrigerated vaccine in a refrigerator or failure to store frozen vaccine in a freezer
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
VACCINE MANAGEMENT
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Standard Operating Procedures (SOP)Providers must have a written SOP in place for proper vaccine management.
• The SOP must be reviewed and updated annually or when there is a change in responsible staff.
• SOP should include procedures for▫ Proper storage and handling▫ Vaccine ordering, inventory control and receiving▫ Vaccine relocation in the event of power or equipment failure▫ Handling damaged or expired vaccines▫ Response and documentation to temperature excursions
All staff who are responsible for vaccines in any way must acknowledge reading their practice’s SOP by signing and dating the document.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Recommended Storage TemperaturesThe cold chain must not be broken, vaccines must remain at
proper temperatures between:Manufacturer Distributor Office/Clinic Patient
If temperature is colder than:2°C (35°F) for >15 Minutes
If temperature is warmer than:8°C (46°F) for > 30 Minutes
If temperature is warmer than:-15°C (+5°F) for >60 Minutes
FREEZERREFRIGERATOR
ImmediatelyUpload temp logs into MIIS and call the Vaccine Unit at 617-983-6828 if
temperatures are out of range.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Storage Units
• All refrigerator storage units are required to be pharmaceutical grade▫ Purpose-built units can also be used to store state supplied vaccine. They are
designed specifically for the storage of vaccines.• Frozen vaccine must be stored in stand-alone freezers
▫ Stand-alone freezers can be very small, the size of a microwave in some cases. ▫ MDPH Immunization Division recommends that MMR is stored in a freezer.
If the immunization division identifies that your storage unit does not meet these requirements, your ability to order will be limited.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Storage Tips• Keep vaccines in original manufacturer
packaging.• Organize vaccines by type and
expiration date.• Storage units must be plugged directly
into a wall outlet.• Avoid over-filling refrigerator and
hindering air circulation.• Frequent opening may cause
temperature fluctuations.• Assure doors are always closed and
sealed.2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Digital Data Logger• All storage units that contain state-supplied pediatric vaccines are required to
have a digital data logger monitoring temperatures. • Digital Data Loggers must meet the most up to date standards set by the CDC.
The complete list of the standards are listed on the ‘Guideline for Compliance’. Below are a few examples: ▫ NIST certified calibration▫ Detachable probe with buffer solution▫ Alarm for out-of-range temperatures▫ Digital display that shows current, minimum, and maximum temperatures.▫ The ability for the provider to acknowledge min/max temperature daily.▫ Is able to generate a PDF report that can be uploaded into the MIIS
Report must be easily identify alarms, duration of alarms, and minimum and maximum temperatures.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Data Logger Report• Data logger reports must be uploaded directly into the
MIIS with every vaccine order or MONTHLY.• Urgent temperature issue must be uploaded directly into
the MIIS. • Faxing temperature logs for orders or an urgent issue
could cause a delay in response. • Additionally, uploading reports directly into the MIIS
satisfies the requirement to keep logs for three years.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Monitoring Temperatures• All providers must review the minimum, maximum and current
temperature daily. ▫ By doing this, it will help identify temperature trends and problems with a
storage unit before vaccine loss occurs.• If anyone at the site notices that the refrigerator is running outside of the
recommended ranges, then they must take action by following the SOP.• NEVER adjust a storage unit temperature controls with vaccine in the
unit.▫ Always contact the Vaccine Management Unit when moving vaccines.
• Contact the Vaccine Management Unit with any questions.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Expired/Damaged Vaccine• Report expired or damaged vaccine through the
‘Storage/Handling Issues’ function in the MIIS.▫ Immediately remove from the refrigerator/freezer. ▫ Label ‘DO NOT USE’.▫ Package for return to McKesson.
• Open/contaminated vaccine does not need to be returned, but still needs to be reported in the MIIS.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Reporting Expired/Damaged Vaccine• Vaccine can be reported either in the beginning of a new order or as a
separate storage and handling issue.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Examples of Storage/Handling Issues
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Transferring Vaccines• Providers should aim to have no
expired vaccine.• Vaccines that are expiring soon
will be highlighted orange and vaccines that are expired will be highlighted red in the MIIS.
• If a provider cannot use vaccine prior to expiration, the vaccine should be transferred to another enrolled provider.
• Transfers must be processed via the MIIS.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Transporting Vaccine1
• Contact back up storage location to make sure they can accommodate your vaccines.
2• Obtain hard sided or Styrofoam cooler and label outside of cooler “Must Store in Fridge” or “Must Store in Freezer”
3• Place COLD packs in the bottom of cooler. Place bubble wrap or cardboard on top of the cold packs. DO NOT USE ICE
PACKS for Refrigerated Vaccine
4• Retrieve your Data Logger and place the glycol vial into the cooler. Keep Data Logger display outside of cooler.
5• Place vaccine boxes on top of bubble wrap/cardboard. Cover vaccines with another layer of bubble wrap/cardboard.
6• Document the time and temperature of vaccine when placed in transporting container. Also document the time and
temperature of vaccine when placed in back up unit.*
7• Contact the MDPH Vaccine Unit at (617)983-6828 with transport information.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Ordering • Select ‘Order’ in MIIS.• Create a new order.• Process any expired or damaged vaccines• Print Vaccine Inventory Worksheet.
• Reconcile Inventory.• Request vaccines and add notes to vaccine unit if necessary.• Upload temp logs for all storage units.• Confirm Shipping address and hours.• Submit.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Recommended RequestThe ‘recommended request’ is a recommendation of the number of doses that a site should order to maintain a 2 to 2.5 month inventory.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Arrival
Alert office staff to expect
vaccine shipment
within 2 weeks after vaccine
order is approved.
When shipment
arrives, open the box
immediately.
Check the temperature monitors – if
there is a problem, call Vaccine Unit immediately.
Verify packing list matches your vaccine
order – if there is a problem,
call the Vaccine Unit
immediately.
Place vaccines in appropriate storage units.
Maintain packing lists for at least 3
years.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Responsibilities of Provider• Medical Director
▫ Responsible for ensuring that state-supplied vaccine is administered in compliance with federal requirements for administration of vaccine.
▫ Ensuring that annual enrollment is completed in order to receive vaccines. ▫ Understands and agrees that MDPH Immunization Division staff are required to make site
visits.▫ Responsible for designating a Primary and Back-up Vaccine coordinator.
• Primary and Back-Up Vaccine Coordinator▫ Responsible for all oversight of all vaccine storage and handling including vaccine ordering
and acting as the vaccine shipping contact.▫ Responsible for communicating vaccine policy, vaccine availability, updates and alerts to
staff.
Any changes in the Primary or Back-up Vaccine Coordinator must be reported within 10 days.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Annual Enrollment• Completed in the MIIS.• Complete the following fields:
▫ Practice Profile▫ Shipping address and hours of operation ▫ Update all providers on the Provider List Tab and select the Provider Type
for all providers listed (Adult, Pediatric, or Pediatric/Adult)• Confirm required fields are still accurate:
▫ Primary and Back-up Vaccine Coordinator and title (ex: MA, CMA, RN etc.)▫ Medical Director names and e-mail address
• Ensure that at least the Primary and Back-up Vaccine Coordinator at your practice has received a VFC Compliance and Storage and Handling training and received a certificate during the previous year.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Site Visit• MDPH Immunization Division conducts site visits for practices every 2 years.• Sites are assessed for compliance with VFC and other federal requirements in
accordance with MDPH guidelines.• If any problems are identified with VFC compliance, the site is entered into an
educational follow-up process in accordance with CDC guidelines.• At the end of the visit, providers will receive a Provider Follow-up Plan and it
must be signed by the Medical Director (or staff authorized to sign on behalf of the organization).
• MDPH is required to complete a certain number of unannounced visits each year.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Documentation• Records related to the immunization division should be kept for at least
three years. ▫ Patient eligibility▫ Temperature logs (maintained in MIIS) and Vaccine packing slips▫ Borrowing Report▫ Temperature Troubleshooting Logs
• Providers must ensure that the permanent medical record of the recipient contains all the required documentation for immunizations.▫ Requirements for retention of written documentation vary and depend on
licensing requirements.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Billing and Charging for State-supplied Vaccines
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Billing and Charging for State Supplied Vaccine
• The vaccine administration fee is up to $23.29 per dose for non-Medicaid VFC-eligible patients.
• Providers may not bill for the cost of any state-supplied vaccines.
• Providers may not deny state-supplied vaccine to an established patient due to the inability to pay the administration fee.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Clarification of billing practices in the VFC Program
• Starting January 1, 2020, providers who bill vaccine administration fees to non-Medicaid VFC-eligible children after the date of service may issue only a single bill to the patient within 90 days of vaccine administration.
Patients cannot be turned away or reported to collections for the inability to pay the vaccine administration fee.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Information Statements (VIS) and Consent
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Information Statements (VIS)All providers are required to provide a copy of the relevant, current edition of the VIS produced by the CDC before administering a doses of vaccine (NCVIA: 42 U.S.C. Section 300aa-26).
• Copies of the most recent VIS can be found at www.immunize.org/vis or on the CDC website at www.cdc.gov/vaccines/hcp/vis/.
• Sign up to receive emails when VISs are updated at www.cdc.gov/vaccines/hcp/vis.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Information Statements (VIS)All providers must maintain copies of the most up to date VISs in their office.
www.cdc.gov/vaccines/hcp/vis/2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine SafetyAdverse events should be reported via the Vaccine Adverse Events Reporting System (VAERS).• Providers can report directly to VAERS by going to the VAERS
website: https://vaers.hhs.gov/ or calling 800-822-7967.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Vaccine Management Monthly Updates• The Vaccine Management Unit sends out monthly
updates that include information about vaccine supply, upcoming dates, and other important information.
• Please ensure that you are reading these updates.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
Please Call With Any Questions• The Vaccine Management Unit can be reached at
617-983-6828 with any issue relating to vaccine availability, storage, or handling.
• The MIIS Help Desk can be reached at 617-983-4335 with any questions regarding the immunization registry.
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training
To all of the Medical Directors, Primary and Back-up Vaccine Coordinators, RNs, MAs, other office staff involved with
immunizations at provider offices,Thank you for all you do to take care of vaccines and, in turn,
take care of your patients and protect them from vaccine preventable diseases!
2020 Enduring Webinar: Storage & Handling_VFC Compliance Training