Hepatitis Caucus Co-Chairs Reps. Johnson, Velázquez Urge CMS To Improve Hep B Vaccine Access

Lawmakers Encourage Expanded Medicare Beneficiary Vaccine Access 

WASHINGTON, D.C. – Today, Congressman Hank Johnson (GA-04) and Nydia M. Velázquez (NY-07), co-chairs of the Hepatitis Caucus, sent a letter to Centers for Medicare & Medicaid Services urging them to expand access for seniors to the hepatitis B virus (HBV) vaccination.

The letter, addressed directly to CMS Administrator Chiquita Brooks-LaSure, stated: “CMS has the authority through this rulemaking to expand the mass immunizer program to include all current and future Part B preventive vaccines, and specifically, alleviate long-standing barriers to hepatitis B virus (HBV) vaccination. We believe Medicare seniors and the disabled with intermediate to high risk factors for HBV would benefit from receiving HBV vaccines in mass immunizer sites, such as pharmacies, without the physician order requirement.”

The lawmakers’ letter lifted up viral hepatitis advocates, who are urging CMS to make a small fix that would improve hepatitis B vaccine access in Medicare Part B. Currently, HBV vaccines are the only vaccines not included in the Part B “mass immunizer” program. This program allows vaccines to be delivered through Part B in a variety of sites that are convenient for the Medicare beneficiary, such as pharmacies. By not being included, HBV vaccines must be delivered in primary care, resulting in missed opportunities for patients to receive a potentially lifesaving vaccine in environments that work best for them.

Cosigners of the letter include Reps. Alma Adams (NC-12), Don Beyer (VA-08), Sanford Bishop (GA-02), Sheila Cherfilus-McCormick (FL-20), Yvette Clarke (NY-09), Dwight Evans (PA-03), Grace Meng (NY-06), Eleanor Holmes Norton (DC), Barbara Lee (CA-12), Adam Smith (WA-09), Eric Swalwell (CA-14), Bonnie Watson Coleman (NJ-12), and Frederica Wilson (FL-24).

Endorsing Organizations: Access Support Network, African Family Health Organization, American Association for the Study of Liver Diseases (AASLD), American Pharmacists Association (ApHA), Any Positive Change, Inc., Asian Liver Center at Stanford University, Asian Pacific Community in Action, Association of Asian Pacific Community Health Organizations (AAPCHO), B-Free Houston, Balanced Imperfection, Being Alive - LA, California Hepatitis Alliance, Canon Senior Center, Caring Ambassadors Program, Community Liver Alliance, Community Youth Center, Delaware County Community Health, End Hep C SF, End The Epidemic: Californians Mobilizing to End HIV, Viral Hepatitis, STIs, and Overdose, Glide SF, Global Liver Institute, GPHA, Greater Philadelphia Health Action, Hawai’i Health and Harm Reduction Center, HBI-DC, Hep Free Hawai’i, Hepatitis B Foundation, Hepatitis C Allies of Philadelphia (HepCAP), Hepatitis C Mentor and Support Group - HCMSG, HIV+Hep, Legacy Community Health, Liver Coalition of San Diego County, Mid-South Liver Alliance, NASTAD, National Asian Pacific American Families Against Substance Abuse (NAPAFASA), National Harm Reduction Coalition, National Task Force on Hepatitis B, National Viral Hepatitis Roundtable (NVHR), Pennsylvania Public Health Association, Pennsylvania Society of Gastroenterology, Prevention Point Pittsburgh, San Francisco AIDS Foundation, Self Help for the Elderly, SF Hep B Free - Bay Area, The AIDS Institute, Trans Legal Aid Clinic Texas, Treatment Action Group, Virginia Harm Reduction Coalition, Will Rodgers Liver Health Foundation.

Read the letter HERE or below. 

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244
 
Dear Administrator Brooks-LaSure:

As we honor Hepatitis Awareness Month, we write to request that the Centers for Medicare & Medicaid Services (CMS) consider improving Medicare beneficiary vaccine access through changes in the upcoming Calendar Year (CY) 2025 Medicare Physician Fee Schedule (MPFS). 

CMS has the authority through this rulemaking to expand the mass immunizer program to include all current and future Part B preventive vaccines, and specifically, alleviate long-standing barriers to hepatitis B virus (HBV) vaccination. We believe Medicare seniors and the disabled with intermediate to high risk factors for HBV would benefit from receiving HBV vaccines in mass immunizer sites, such as pharmacies, without the physician order requirement. 

These important policy changes would bring us closer to national viral hepatitis elimination goals set forth by the Department of Health and Human Services (HHS), universal adult HBV vaccination as recommended by the Centers for Disease Control (CDC) Advisory Committee on Immunization Practices (ACIP), the Federal Implementation Plan to eliminate vaccine-preventable diseases and helps overcome health equity disparities in Medicare and among adults. 

It is estimated that 800,000 – 1.9 million people in the United State are living with HBV, with two-thirds being unaware of their statues. HBV also disproportionately impacts the Asian American communities. While Asian Americans make up 6% of the U.S. population, they account for more than 60% of people with chronic HBV infection. Furthermore, people from racial and ethnic minorities are disproportionately affected when it comes to receiving recommended vaccines. Research has shown that racial minorities, older adults, and people with disabilities are more likely to have transportation services to primary health care services but would benefit from being able to receive their HBV vaccines when visiting drug stories and pharmacies.

HBV vaccines are covered under the Medicare Part B medical benefit; however, they are treated differently from all other Medicare Part B preventive vaccines. HBV vaccines are excluded from being administered and reimbursed by mass immunizers, and a physician order is required for HBV vaccines to be covered. All other preventive Part B vaccines, including influenza, pneumococcal and COVID-19 vaccines, are eligible for administration and reimbursement by mass immunizers without a physician order requirement. 

Despite coverage under the Medicare Part B medical benefit, risk-based guidelines and the physician order requirement have served as barriers for HBV vaccination. The ACIP recommendation for vaccination included adults ≥60 years with risk factors for hepatitis B and adults aged ≥60 years without known risk factors for hepatitis B may be vaccinated. Yet, HBV vaccine coverage remains low within the Medicare population. Currently, only 19.5% of adults ages 60 years and older are vaccinated against HBV, even though many Medicare beneficiaries have known risk factors (e.g., 28% of beneficiaries are diagnosed with diabetes mellitus). 

Expanding HBV vaccination would result in prevention of infections and associated cost savings. Given the role that mass immunizers, particularly pharmacists, carry out in providing most vaccinations to Medicare beneficiaries, patients expect that they can access these vital healthcare services at their local pharmacy, particularly in underserved communities, where the neighborhood pharmacy may be the only healthcare provider for miles. Lack of HBV vaccination access in a pharmacy setting for those Medicare Part B beneficiaries with risk factors is an outlier compared to most other adult populations, including Medicare beneficiaries without risk factors, most Medicaid beneficiaries and those adults with private health insurance. By permitting Hepatitis B vaccination by mass immunizers, including pharmacists, vulnerable seniors and the disabled, who have added challenges to completing multiple dose series, can more easily be protected from this preventable disease.

Policies that encourage HBV vaccination are needed in order to expand the number of people that will get vaccinated. Achieving equitable protection for Medicare beneficiaries from this preventable disease is almost impossible without allowing HBV vaccines to be included in the mass immunizer program. We believe expanded access to HBV vaccination in the pharmacy setting will help move the needle for this vulnerable population.

Therefore, we recommend that CMS take steps to facilitate enhanced beneficiary access to HBV vaccines by clarifying that a physician order is not necessary for HBV vaccines to be covered and allowing mass immunizer administration and reimbursement of HBV vaccines.
  
cc: The Honorable Xavier Becerra, Secretary, Department of Health and Human Services

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