2016 MnVFC Site Visit Questionnaire Date of visit: Date forms sent to MDH: Site Information Site name: MnVFC PIN: Site address: ☐ Separate Stock ☐ Replacement City: ZIP: County: Medical director: Immunization manager: Phone: Email: Vaccine coordinator: Phone: Email: Vaccine coordinator back-up: Email: Point of contact: Phone: Email: Personnel at site visit: IPI Advisor Information (staff that performed visit) IPI Advisor: Phone: County: Email: Post Visit Steps Education on Immunization Best Practices for Sites Required forms sent to MDH within 10 days of visit (Email to health.ipi.inquiries@state.mn.us or fax to 651-201-5501): ☐ MnVFC Site Visit Questionnaire ☐ Storage & Handling Per Unit Answer Sheet Number sent: ☐ Provider Follow-up Plan with signature Required forms sent to site: ☐ Thank you letter with survey link ☐ Continuing education importance and resources ☐ Folder given with clinical information ▪ Guide to Contraindications and Precautions to Commonly Used Vaccines ▪ How to Administer IM/SQ Injections To be completed by MnVFC clinical coordinator/planner at MDH Date reviewed: Signature: Site type: ☐ Private ☐ Public Health ☐ Hospital ☐ Pharmacy ☐ FQHC/RHC ☐ Tribal/IHS ☐ School-based ☐ Correctional Facility ☐ Mass Vaccination Program IM M UNI ZA T IO N P RA CT I C E S IM PR OV EM E NT (I P I) Site Visit Reviewer Guide Legend Section Number: Content Area Question number: This area will always contain the text of the question Note to reviewer: The note to reviewer contains information that is necessary for properly asking and assessing responses to the question above. This may include definitions of terms, requirement details and other helpful tips. Answers: This field will contain all the possible answer choices for this question. For most questions, answer choices will be followed by the markings below: ▪ Answer choices marked with an [X] indicate that this specific answer choice is non-compliant with a CDC requirement. ▪ Answer choices marked with an [O] indicate that this specific answer choice is not aligned with a CDC recommendation. Review CDC Requirement/Recommendation: This field will be populated with the CDC requirement/recommendation associated with the given question Actions if Non-Compliant: Root Cause Analysis: As part of the site visit, reviewers are required to assess and understand the reasons why a provider office is non-compliant with VFC program requirements – this is a root cause analysis. Reviewers must choose the one root cause that they believe most contributes to the non-compliance. Upon establishing the root cause, the reviewer must provide a clear explanation of his/her findings. Immediate Action: These are actions that CDC requires reviewers to take on site during the visit. Future Follow-up: These are future follow-up actions (with designated due dates) that are required of the reviewer and/or provider to remedy non-compliance. Reviewers must complete all follow-up in accordance with CDC established deadlines. 2016 MnVFC Site Visit Questionnaire (May 2016) Page 2 of 30 1. Provider Details: Changes to Key Staff Question 1.2: A (Choose all that apply) Ask the provider about changes to key staff to answer the questions below. Are the current Medical Director, Immunization ☐ Yes Manager/Vaccine Coordinator, and Back-up ☐ No, the Medical Director has changed Coordinator the same as those documented on ☐ No, the Immunization Manager/Vaccine Coordinator has the Provider Agreement? changed ☐ No, the Back-up Vaccine Coordinator has changed. ☐ Yes, or no staff changes ☐ No [X] B (Choose one) Were all changes communicated to the Immunization Program according to your program’s policy? C (Choose one) Based on review of the training ☐ Yes documentation, have the current Immunization ☐ No [X] Manager/Vaccine Coordinator and Back-up Coordinator completed all required training? Review CDC Requirement: All changes in key staff must be communicated to the Immunization Program in the manner and timeframe defined by the Immunization Program. Key staff include: the Medical Director or equivalent who signed the Provider Agreement; the Vaccine Coordinator, and the Back-up Coordinator. VFC providers are required to ensure that all key staff are fully trained on VFC program requirements at all times. All training must be documented. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Question C: Provide training on key requirements during the site visit. Future Follow-up: ☐ Question C: Staff that have not taken the MnVFC online training must complete it and send the certificate to the IPI advisor within 30 days. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 3 of 30 2. Eligibility: VFC Eligibility Categories Question 2.1: Ask the individual responsible for determining patient VFC eligibility to list all of the VFC eligibility criteria. Was the individual able to list each of the eligibility criteria below? A Patient is less than 19 years of age ☐ Yes ☐ No [X] B Patient is Medicaid-eligible ☐ Yes ☐ No [X] C Patient is uninsured ☐ Yes ☐ No [X] D Patient is underinsured ☐ Yes ☐ No [X] E Patient is American Indian ☐ Yes ☐ No [X] F Patient is Alaska Native ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers must possess a working knowledge of all VFC eligibility criteria and use those criteria to screen children prior to administering VFC vaccines. In order to receive VFC vaccine, a patient must be under the age of 19 and must be at least one of the following: (1) Medicaid-eligible; (2) Uninsured (i.e., child has no health insurance); (3) Underinsured (i.e., child has health insurance, but coverage does not cover any or certain vaccines – underinsured children may only receive VFC vaccines in FQHC/RHC or deputized VFC provider offices and only for vaccines not covered by insurance); and (4) American Indian or Alaska Native (AI/AN). Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Provide educational materials/resources on VFC eligibility requirements. Depending on the findings of the root cause analysis, add follow-up as needed to make sure the issue is addressed. Future Follow-up: Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 4 of 30 2. Eligibility: Billing Practices Question 2.2: Is the individual/department responsible for billing able to clearly explain how they bill for both the cost of vaccine and the vaccine administration fee for each of the eligibility categories below? A Medicaid-eligible Cost of Vaccine: Do not bill – provided by VFC Admin Fee: Bill Medicaid ☐ Yes ☐ No [X] B Uninsured Cost of Vaccine: Do not bill – provided by VFC Admin Fee: If billing, can bill patient ☐ Yes ☐ No [X] C Underinsured Cost of Vaccine: Do not bill – provided by VFC through FQHCs, RHCs or deputized providers only; all other providers cannot provide VFC vaccine to underinsured patients Admin Fee: If billing, can bill patient ☐ Yes ☐ No [X] D American Cost of Vaccine: Do not bill - provided by VFC unless patient is fully Indian/Alaska Native insured and parent chooses to use insurance (AI/AN) ☐ Yes Admin Fee: If patient is Medicaid-eligible, bill Medicaid; if billing, and patient is uninsured/underinsured, can bill patient; if parent ☐ No [X] chooses to use private insurance for cost of vaccine, bill patient/insurance E Do individuals responsible for billing have access to the results of eligibility screening to ensure proper billing? ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers must adhere to proper billing practices for vaccine administration fees and clearly understand that VFC vaccine is provided at no cost to both the VFC provider and eligible children. At no time should billing occur for the cost of VFC vaccine. When administering VFC vaccine, providers should never bill two different “payers” (i.e., patient, Medicaid, insurance) for the same vaccine administration fee amount. For Medicaid-eligible children, Medicaid should be billed for the vaccine administration fee. For all other VFC-eligible populations, the patient may be billed within the state/territory cap established by the Centers for Medicare and Medicaid (CMS). However, established patients cannot be turned away or reported to collections for inability to pay the administration fee. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ If you have concerns about improper billing, conduct a record review to better understand billing practices and add follow-up as appropriate based on your root cause findings. Call MDH at 651-201-5522 if you need assistance. Future Follow-up: ☐ Provider to submit in no later than one month: New or revised billing protocols addressing how your office will bill for each VFC-eligible category. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 5 of 30 2. Eligibility: Vaccine Administration Fee Question 2.3: Answers: Document the actual vaccine administration fee charged to non-Medicaid, VFC-eligible patients (confirm with billing department). Fee: $ [X] Follow-up is required if the provider charges more than the fee cap established by the Centers for Medicare and Medicaid (CMS) for your state/territory ($21.22). Review CDC Requirement: The VFC provider’s vaccine administration fee for non-Medicaid, VFC-eligible children must not exceed the state/territory vaccine administration fee cap established by the Centers for Medicare and Medicaid (CMS). For current fee caps, refer to Medicaid Program; Payments for Services Furnished by Certain Primary Care Physicians and Charges for Vaccine Administration Under the Vaccines for Children Program, Final Rule (http://www.gpo.gov/fdsys/pkg/FR-2012-11-06/pdf/2012-26507.pdf). Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Future Follow-up: ☐ 6 month: Perform follow-up site visit to assess whether the provider is charging a vaccine administration fee that does not exceed the state CMS fee cap. If the provider continues to bill above the CMS cap, add custom follow-up in PEAR based on Immunization Program protocol. Notes: 3. Documentation: Method of Eligibility Documentation Question 3.1: How does the provider currently document the results of eligibility screening? Answers: (Choose one) ☐ Paper patient records ☐ Electronic records (i.e., EMR/EHR/IIS) ☐ Provider has indicated that they do not screen or document eligibility. Call MDH at 651-201-5522 to discuss situation with MnVFC staff. (Skip to question 3.5) Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 6 of 30 3. Documentation: Eligibility Screening & Documentation Question 3.4: Note to Reviewer: Select a minimum of 10 records that contain an immunization visit in the last six months (12 months if necessary) and review for compliance with VFC eligibility screening documentation requirements (See note to reviewer below). Criteria for Record Selection: 1) Record selection must be completely random: the provider must not know prior to the visit which records will be reviewed 2) Patient must have been 0-19 years of age at the last visit (Note: Records of 19-year-old patients may allow you to see if VFC vaccines are being used beyond the allowable age) Records are Compliant if all the Below Conditions are Met: 1) Contains patient’s date of birth (and/or age) 2) Contains date of the immunization 3) Contains patient’s specific VFC eligibility category (Medicaid-eligible, uninsured, underinsured, AI/AN) or ineligibility category associated with the date of that specific immunization visit 4) If marked as VFC-eligible, contains no evidence of insurance coverage (unless patient is (1) AI/AN with private insurance; (2) patient has Medicaid as secondary insurance; (3) patient is underinsured and provider is deputized) 5) If patient is over the age of 18, not marked as VFC-eligible A Number of records reviewed: B Number of compliant records (See note to reviewer): If fewer than 10 records are reviewed, select the reason why: ☐ Provider does not have 10 patient records with immunizations in last 12 months [X] Follow-up is required if one or more records do not meet requirements C Does the provider’s screening process ensure that patients are screened for VFCeligibility at each visit and that screening results are documented at each visit? ☐ Yes ☐ No [X] D Does the provider’s process ensure that staff drawing and administering vaccine know which vaccine stock to select from? ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers must screen for and document VFC eligibility at each immunization visit. Documentation must include all elements present on the CDC Eligibility Screening Form (i.e., date of the visit and the specific eligibility category). VFC providers must use screening results to ensure that only VFC-eligible children receive VFC vaccine and that administration fees are billed for as appropriate. Eligibility status must be readily available to staff administering vaccine prior to selecting which vaccine stock to use. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Provide guidance on establishing a screening process and add follow-up as appropriate based on your root cause findings. Future Follow-up: ☐ Provider to submit in no later than one month: New or revised protocols for conducting and documenting eligibility screening for each patient at each visit. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 7 of 30 3. Documentation: Vaccine Dose Documentation Question 3.5: Note to Reviewer: Review a minimum of 10 patient immunization records from the last six months (or 12 months if necessary) to assess compliance with documentation requirements set forth by Statute 42 US Code 300aa-25 (See note to reviewer below). Criteria for Record Selection: 1) Record selection must be completely random: the Provider must not know prior to the visit which records will be reviewed 2) Patient must have been 0-19 years of age at the last visit (Note: Records of 19-year-old patients may allow you to see if VFC vaccines are being used beyond the allowable age) Records are Compliant if they Contain ALL the Below Elements: Address of clinic where vaccine was administered Name of vaccine administered Date vaccine was administered Date VIS was given Publication date of VIS Name of vaccine manufacturer Lot number Name and title of person who administered the vaccine A Number of records reviewed: B Number of records that contain ALL required documentation elements: If fewer than 10 records are reviewed, select the reason why: ☐ Provider does not have 10 patient records with immunizations in last 12 months [X] Follow-up is required if one or more records do not meet requirements Review CDC Requirement: In accordance with Federal law, all VFC providers must maintain immunization records that include ALL of the following elements: (1) name of vaccine administered; (2) date vaccine was administered; (3) date VIS was given; (4) publication date of VIS; (5) name of vaccine manufacturer; (6) lot number; (7) name and title of person who administer the vaccine; (8) address of clinic where vaccine was administered. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Discuss with the provider how to improve their processes to ensure that all required fields are documented for each dose of vaccine administered and add follow-up as appropriate based on your root cause findings. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 8 of 30 3. Documentation: Record Retention Question 3.6: Is the provider able to demonstrate (preferred) or clearly describe how they maintain historical VFC eligibility documentation for three years? Answers: (Choose one) ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers are required to maintain all records related to the VFC program for a minimum of three years (or longer if required by state law) and upon request make these records available for review. VFC records include, but are not limited to, VFC screening and eligibility documentation, billing records, medical records that verify receipt of vaccine, vaccine ordering records, and vaccine purchase and accountability records. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Future Follow-up: ☐ Provider to submit in no later than one month: Plan for maintaining historical patient eligibility documentation for a minimum of three years (or longer if required by state law). Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 9 of 30 3. Documentation: Borrowing Documentation Question 3.7: Note to Reviewer: Discuss borrowing practices with the provider to answer the questions below. To be considered “fully documented,” documentation for each borrowed dose must include the following information: ▪ Vaccine type borrowed ▪ Stock used (VFC or private) ▪ Patient name and date of birth ▪ Date the dose was administered ▪ Reason appropriate vaccine stock was not used ▪ Date dose was returned to appropriate stock A Did the provider state that they had borrowed any vaccines (whether documented or not) since the last VFC Compliance Site Visit? ☐ Yes ☐ No (If no, skip to question 3.9) B Were all borrowed doses fully documented? (See Note to Reviewer above) ☐ Yes ☐ No [X] C Were all borrowed VFC doses replaced? ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers are expected to maintain an adequate inventory of vaccine for VFC and non-VFC-eligible patients – it is the responsibility of the VFC provider to appropriately schedule and place vaccine orders. VFC providers must also rotate stock to ensure timely use of short-dated vaccines. Borrowing of vaccine between private and public inventories must be a rare, unplanned occurrence and cannot serve as a replacement system for a VFC provider’s privately purchased vaccine inventory. All instances of borrowing must be properly documented, reported and replaced. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Question B: Follow Immunization Program policy on borrowing and provide instruction for proper reporting, documentation, and replacement. Leave a borrowing form with the provider with instruction on use if applies. Future Follow-up: ☐ Question B: Provider to submit in six months: Borrowing reports for the six months since the site visit. ☐ Question C: Provider to submit in no later than one month: Documentation of purchase of private stock used to replace borrowed VFC doses. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 10 of 30 3. Documentation: Borrowing Reasons Question 3.8: Based on your discussion with the provider and a review of borrowing reports, document the doses borrowed for each reason and answer the questions below. Note to Reviewer: Short-dated vaccines are doses that are likely to expire before they can be used. Exchanging short-dated vaccines should only occur in practices that have a small number of private patients. A Reasons for Borrowing a VFC Dose: (Enter the number of Private vaccine shipment delay (order placed on time, but delay in shipping/receipt) vaccine doses Private vaccine not useable on arrival (vials broken, temperature monitor out of range) borrowed for each Ran out of private vaccine between orders (provider orders not placed on time) [X] reason in the spaces Short-dated private dose was exchanged with VFC stock provided) Accidental use of VFC dose for a private patient (human error) Replacement of private dose with VFC when insurance plan did not cover vaccine Other (Explanation Required): [X] Reasons for Borrowing a Private Dose: VFC vaccine shipment delay (order placed on time, but delay in shipping/receipt) VFC vaccine not useable on arrival (vials broken, temperature monitor out of range) Ran out of VFC stock between orders (provider orders not placed on time) [X] Short-dated VFC vaccine dose was exchanged with private dose Accidental use of a private dose for a VFC-eligible patient (human error) Other (Explanation Required): [X] B C Enter the date range of the instances of borrowing reviewed in the borrowing report. NOTE: If “Date of earliest instance” is not available, use the date of the last VFC Compliance Visit. If “Date of last instance” is not available, use the date of the current VFC Compliance Visit. Date of earliest instance: Date of last instance: Does borrowing appear to be a routine practice? Note: To determine whether borrowing is a routine practice, assess frequency of ☐ Yes [X] and repeating reasons for borrowing. ☐ No Examples: Frequent accidental use of incorrect stock, exchanging short-dated vaccines or issues with ordering and shipment Review CDC Requirement: VFC providers are expected to maintain an adequate inventory of vaccine for VFC and non-VFC-eligible patients – it is the responsibility of the VFC provider to appropriately schedule and place vaccine orders. VFC providers must also rotate stock to ensure timely use of short-dated vaccines. Borrowing of vaccine between private and public inventories must be a rare, unplanned occurrence and cannot serve as a replacement system for a VFC provider’s privately purchased vaccine inventory. All instances of borrowing must be properly documented, reported and replaced. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Future Follow-up: ☐ Provider to submit in no later than one month: New or revised protocols for managing vaccine ordering and inventory and other internal processes to prevent routine borrowing. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 11 of 30 3. Documentation: Vaccine Management Plan Question 3.9: Physically review the provider’s Vaccine Management Plan to answer the question below. A Does the provider have a Vaccine Management Plan? ☐ Yes ☐ No [X] (If no, skip to question 3.10) B Does the plan list the current Vaccine Coordinator and Back-up Coordinator? ☐ Yes ☐ No [X] C Does the plan address proper vaccine storage and handling practices? ☐ Yes ☐ No [X] D Does the plan specify vaccine receiving procedures? ☐ Yes ☐ No [X] E Does the plan contain procedures for what to do with vaccine in the event of an emergency? ☐ Yes ☐ No [X] F Does the plan contain procedures for vaccine ordering? ☐ Yes ☐ No [X] G Does the plan address inventory control (example: stock rotation)? ☐ Yes ☐ No [X] H Does the plan address how to handle vaccine wastage? ☐ Yes ☐ No [X] I Does the plan address staff training and documentation on vaccine management, storage & handling? ☐ Yes ☐ No [X] J Does the plan contain a review date that falls within the last 12 months? ☐ Yes ☐ No [X] K Has the plan been signed by the individual responsible for its content? ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers must develop, maintain and implement a Vaccine Management Plan for routine and emergency vaccine management. The plan must contain: the current Vaccine Coordinator and Back-up Coordinator; proper storage and handling practices; shipping and receiving procedures; emergency procedures; procedures for vaccine ordering; inventory control (e.g., stock rotation); how to handle vaccine wastage; and staff training/documentation on vaccine management, storage and handling. The plan must be reviewed/updated annually or more frequently if changes occur. A “review date” and signature are required on all plans in order to validate that they are current. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Provide a copy of the Immunization Program Vaccine Management Plan and/or Vaccine Emergency Plan template(s). Future Follow-up: ☐ Provider to submit in no later than one month: Updated and complete Vaccine Management Plan Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 12 of 30 3. Documentation: VIS & VAERS Question 3.10: Review the provider’s Vaccine Information Statements (VIS) and discuss provider’s VAERS process to answer the questions below. A Does the provider have readily available, up-to-date VIS for all ACIP-recommended vaccines relevant to the populations it serves? ☐ Yes ☐ No [X] B Does the provider make VIS available for patients/parents prior to each vaccination? ☐ Yes ☐ No [X] C Does the provider know how and when to report clinically significant adverse events using VAERS? ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers are required to distribute the current Vaccine Information Statements (VIS) each time a vaccine is administered and maintain records in accordance with the National Childhood Vaccine Injury Act (NCVIA), which includes reporting clinically significant adverse events to the Vaccine Adverse Event Reporting System (VAERS). For a list of current VISs, visit CDC’s Vaccine Information Statements (http://www.cdc.gov/vaccines/hcp/vis/) website. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Question A-B: Provide missing VIS by showing provider the online repository on CDC’s Vaccine Information Statements (http://www.cdc.gov/vaccines/hcp/vis/) website or leaving a hard-copy. ☐ Question C: Educate provider on how to report adverse events using the VAERS form or online process. Supply hard copy of the form or refer provider to the VAERS: Report an Adverse Event (https://vaers.hhs.gov/esub/index) page. Notes: 3. Documentation: Anaphylaxis protocol Question 3.11: Answers: (Choose one) Does the site have an anaphylaxis protocol which is clearly posted near the emergency kit? ☐ Yes ☐ No [X] Review CDC Requirement: An anaphylaxis protocol must be clearly posted in the area where vaccines are administered. Immediate Action: ☐ Educate the provider about the requirement for an anaphylaxis protocol. Future Follow-up: ☐ Provider to submit in no later than one month: Complete anaphylaxis protocol. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 13 of 30 NOTE: The sections that follow require reviewers to validate responses by looking at vaccine storage units, temperature monitoring equipment, and the vaccine inventory inside a unit. For section 4, use a separate Storage & Handling Per Unit Answer Sheet for each unit to document the findings (combination units using both sections can be documented on the same answer sheet). When an unmet requirement is identified, return to this questionnaire to complete the “Actions if Non-compliant” section for that question. After you complete one answer sheet for each unit, return to the questionnaire to complete sections 5 and 6 using information you gathered while assessing the units. The questions in sections 5 and 6 (Storage & Handling Site-Wide and Inventory) are not unit-specific but do require that the response be based on a thorough assessment of all the providers’ units. 4. Storage & Handling Per Unit Description On the Storage & Handling Per Unit Answer Sheet, place a name that will allow you or someone else from your program to easily identify this unit in the event of follow-up. We recommend using Brand + Location (example: Samsung - Room 123). ▪ Save each Storage & Handling Per Unit Answer Sheet with the Brand + Location in the file name (example: Samsung.Room123.doc). 2016 MnVFC Site Visit Questionnaire (May 2016) Page 14 of 30 4. Storage & Handling Per Unit: Storage Unit Build & Use Question 4.1: Note to Reviewer: Below, select the build and use of the vaccine storage unit you are assessing. Dorm-Style Units: Do not complete Section 4. Dorm-style units will be addressed in Question 5.2. A dormitory-style refrigerator is a unit that has both refrigerator and freezer compartments behind a single exterior door. Dorm-style units also have an evaporator plate (cooling coil), which is usually located inside an icemaker compartment (freezer) within the refrigerator. A What type of unit is this? A. Stand-alone B. Combination B Select use if stand-alone: A. Freezer B. Refrigerator Select use if combination: A. Use both sections to store vaccine B. Use freezer section only to store vaccine C. Use refrigerator section only to store vaccine 4. Storage & Handling Per Unit: CDC-Recommended Storage Units Question 4.2: Below, document the grade of the vaccine storage unit you are assessing. Note to Reviewer: Pharmaceutical: Also called “purpose-built,” these units are designed by the manufacturer specifically to store vaccines or other biological materials. Commercial: Although usually intended to store food and beverages, commercial units are often larger and more powerful than the household units found in most homes. Though these units are intended to meet the higher demands of larger facilities, these units are not specifically built for the storage of biological materials. Household (non-commercial/domestic): These units are usually smaller than commercial units and are intended for use in small offices and in homes – typically for food storage. However, just like commercial units, they are not designed specifically for the storage of biological materials. Such units are usually available in common home supply stores. Answers: (Choose one) Select grade: A. Pharmaceutical [O] CDC does not recommend the use of both sections, or the B. Commercial/Household freezer section only, of combination commercial/household units. Review CDC Recommendation: CDC recommends the following vaccine storage unit types (in order of preference): pharmaceutical grade stand-alone or combination units (preferred); household/commercial stand-alone units; household/commercial combination units using the refrigerator section only. 2016 MnVFC Site Visit Questionnaire (May 2016) Page 15 of 30 4. Storage & Handling Per Unit: Temperature Monitoring Device in the Unit Question 4.3: Determine whether there is a temperature monitoring device in this section of the storage unit and answer the questions. A Is there a temperature monitoring device in this section of the Yes storage unit? No [X] (Complete question B below and then skip to question 4.7) B Who is responsible for supplying the temperature monitoring device in this section of the storage unit? Provider Review CDC Requirement: Certificates of calibration testing provide confidence that the temperature monitoring device is measuring temperatures accurately. All units storing VFC vaccines must have a calibrated temperature monitoring device with a current and valid certificate of calibration testing. All certificates must contain: model/device name or number, serial number, date of calibration testing (report or issue date), and Instrument Passed testing (Instrument in Tolerance). Recommended uncertainty = +/-0.5º C (+/-1º F). Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Call MDH at 651-201-5522 to discuss situation with MnVFC staff. Future Follow-up: ☐ Provider to submit in no later than one month: (1) Receipt of purchase of a new temperature monitoring device, (2) a copy of the certificate of calibration testing, and (3) one week of complete temperature documentation using the new temperature monitoring device. ☐ Reviewer within one week: If the provider lost storage space due to the absence of a temperature monitoring device, discuss with the Immunization Program whether there is a need to adjust vaccine order quantities for this provider until the provider is able to validate that they have sufficient space for vaccine storage. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 16 of 30 4. Storage & Handling Per Unit: CDC-Recommended Temperature Monitoring Device Question 4.4: Assess the temperature monitoring device in this section of the storage unit to answer the questions below. A Is the temperature monitoring device a continuous monitoring and recording device with a detachable probe in buffered material (e.g., data logger)? Yes No [O] (Skip question D) B Does the temperature monitoring device have a probe in buffered material? Yes No [O] C Does the temperature monitoring device have a digital display that can be easily read from the outside of this unit? Yes No [O] D Is data downloaded and reviewed routinely? Yes No [O] Review CDC Recommendation: CDC recommends the use of a continuous temperature monitoring and recording device with a detachable probe in a buffered material and a digital display that can be easily read from the outside of the unit. Routine review and accessibility of temperature data is critical for determining whether vaccine has been properly stored and for assessing usability of vaccine that was involved in an excursion. As of January 1, 2018, all enrolled VFC providers must use a continuous temperature monitoring and recording device within storage units that store vaccine provided through the VFC program. When selecting a data logger, CDC also recommends the following features: Alarm for out-of-range temperatures Current, minimum and maximum temperatures Low battery indicator Accuracy of +/- 1° F (0.5° C) Memory stores at least 4,000 readings Probes should be placed in buffered material so that they measure temperatures that are more representative of the temperature of the vaccine in the vial rather than the air temperature of the storage unit. Examples of buffers include: A vial filled with liquid (Example: glycol, ethanol, glycerin) A vial filled with loose media (Example: sand, glass beads) A solid block of material (Example: Teflon®, aluminum) CDC does not recommend the following temperature monitoring devices: Fluid-filled bio-safe liquid temperature monitoring devices; Bi-metal stem temperature monitoring devices; food temperature monitoring devices; household mercury temperature monitoring devices; chart recorders; infrared temperature monitoring devices; temperature monitoring devices that are not calibrated. These devices can have significant limitations, can be difficult to read and most only provide information on the temperature at the precise time they are read. Therefore, so temperature fluctuations outside the recommended range may not be detected. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 17 of 30 4. Storage & Handling Per Unit: Certificate of Calibration Testing Question 4.5: Review the certificate of calibration testing for the temperature monitoring device in this section of the storage unit and answer the questions below. Note to Reviewer: How to determine certificate of calibration testing expiration date: 1) Identify the certificate issue/calibration date. 2) Apply the Immunization Program-required frequency for calibration testing. Example: If the issue/calibration date is 12/31/2013 and Immunization Program policy requires testing every two years, the expiration date is 12/31/2015. Certificates must also include all of the below: ☐ Model/Device Name or Number ☐ Serial Number ☐ Date of Calibration Testing (Report or Issue Date) ☐ Instrument Passed testing (Instrument in Tolerance) A Is there a certificate of calibration testing for the temperature monitoring Yes device in this section of the storage unit? No [X] B What is the certificate’s date of expiration based on Immunization Program policy? (See note to reviewer to determine expiration date.) [X] Follow-up is required if certificate is expired C Does the certificate contain all the necessary items listed in the Note to Reviewer? Yes No [X] D Who is responsible for supplying the current and valid certificate of calibration for this temperature monitoring device? Provider Review CDC Requirement: Certificates of calibration testing provide confidence that the temperature monitoring device is measuring temperatures accurately. All units storing VFC vaccines must have a calibrated temperature monitoring device with a current and valid certificate of calibration testing. All certificates must contain: model/device name or number, serial number, date of calibration testing (report or issue date), and Instrument Passed testing (Instrument in Tolerance). Recommended uncertainty = +/-0.5º C (+/-1º F). Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Discuss with the provider how to establish a clear process and specific timelines for ensuring that a temperature monitoring device either undergoes calibration testing or is replaced with a new temperature monitoring device before the certificate of calibration testing expires. Future Follow-up: ☐ Provider to submit in no later than one month: A copy of the current and valid certificate of calibration testing for the temperature monitoring device in this section of the storage unit. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 18 of 30 4. Storage & Handling Per Unit: Probe Placement Question 4.6: Note to Reviewer: Answers: (Choose one) Is the probe properly placed in this section of the storage unit? “Properly” means that the probe in a commercial or household unit is placed in a central area of the unit directly with the vaccines. Probes should not be placed in the doors, near or against the walls, close to vents, or on the floor of the unit. If permissible by the Immunization Program, the only allowable exemption related to this requirement is for providers who have pharmaceutical storage units (built for vaccine storage) that have either: (1) a built-in temperature monitoring device, OR (2) a dedicated port for the probe that dictates the placement of the probe. Yes No [X] Review CDC Requirement: The probe must be placed in a central area of the section of the storage unit directly with the vaccines in order to properly measure vaccine temperature. The probe should not be placed in the door, near or against the walls, close to vents, or on the floor of the unit. For pharmaceutical units with a built-in temperature monitoring device or a dedicated port for a probe that is not in the center of the section of the storage unit, consult your Immunization Program for guidance on placement. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Assist the provider with proper placement of the probe. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 19 of 30 4. Storage & Handling Per Unit: Temperature Documentation Question 4.7: Review the temperature documentation over the past three months for this section of the storage unit to determine whether the provider has a process in place for properly documenting temperatures twice a day. Answer the questions below. A Are there two temperature readings recorded for this section of the storage Yes unit per day? No [X] B Is there a time, date, and name (or initials) recorded for each reading? C What is the current temperature in this section of the storage unit? *Use the reviewer’s thermometer if the provider’s temperature monitoring device: Fahrenheit does not have a probe in buffered solution, Celsius does not have a current, valid certificate of calibration testing, or is not properly placed in the section of the storage unit. D Based on your review of the provider’s recent temperature documentation, Yes including the current temperature, is this section of the storage unit No [X] maintaining appropriate temperatures? Not enough information [X] Yes No [X] Review CDC Requirement: Vaccines must be stored under appropriate temperatures at all times. Acceptable temperature ranges for refrigerated vaccines are 35° F and 46° F (2° C and 8° C) and for frozen vaccines between -58° F and +5° F (-50° C and -15° C). Exposure to temperatures outside of the required ranges can affect vaccine viability and, ultimately, can leave children unprotected against vaccinepreventable diseases. In order to maintain awareness of storage unit temperatures and ensure that vaccines are being stored at appropriate temperatures at all times, VFC providers are required to monitor and document temperatures for all vaccine storage units at least twice a day. Temperature documentation must contain: (1) at least two temperature readings per day, (2) the time and date of each reading and (3) the name (or initials) of the person who assessed and recorded the readings. CDC also recommends that VFC providers using a data logger record the minimum and maximum temperatures of each unit once each workday (preferably in the morning). Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Question A-B: Offer guidance on proper documentation and provide paper log template if needed. ☐ Question D: The vaccine must be moved to a section of a storage unit that: (1) maintains appropriate temperatures; (2) has space available; AND (3) contains a temperature monitoring device with a current, valid certificate of calibration testing. Follow Immunization Program protocol for investigating temperature excursions and contact manufacturer to obtain documentation supporting the usability of the vaccine. Suspend use of the section of the storage unit for vaccine storage until the provider can demonstrate that it maintains appropriate temperatures. Future Follow-up: ☐ Provider to submit in no later than one month: Complete temperature documentation for this section of the storage unit for three weeks since the Compliance Visit. Do not resume use of the unit for storing public vaccine until receiving clearance to do so by the Immunization Program. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 20 of 30 4. Storage & Handling Per Unit: Temperature Excursions Question 4.8: In the event that a temperature excursion(s) occurred in this unit within the last three months, request and review documentation of actions taken to determine whether the provider has a process for properly addressing excursions. Answer the questions below. A Were vaccines in this unit exposed to out-of-range temperatures in the last Yes three months (including today)? No (If no, skip to question 4.8F) B Did the provider quarantine and label vaccines as “Do not use”? C Did the provider place vaccine in a unit where it can be stored under proper Yes conditions? No [X] D Did the provider contact the Immunization Program to report the excursion? Yes No [X] E Was the manufacturer contacted for documentation supporting the usability of the vaccine? Yes No [X] F Based on what you have learned about how the provider manages and monitors for excursions, do you believe any further action is needed to determine the usability of vaccine currently in the unit? Yes [X] No Yes No [X] Review CDC Requirement: The provider must document all excursions and actions taken including the following: (1) Quarantine and label vaccines as “DO NOT USE”; (2) Place vaccines in a unit where they can be stored under proper conditions; (3) Contact the Immunization Program to report an excursion; and (4) Contact the vaccine manufacturer to obtain documentation supporting the usability of the vaccine. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Label vaccines as “DO NOT USE.” Follow Immunization Program protocol for investigating temperature excursions and contact manufacturer to obtain documentation supporting the usability of the vaccine. Add custom follow-up as necessary based on the results of root cause analysis and actions taken on site. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 21 of 30 4. Storage & Handling Per Unit: Vaccine Placement Question 4.9: Look inside the unit to answer the questions below. A Are vaccines placed in the middle of the unit with space between vaccines and the side/back of the unit to allow cold air to circulate? Yes No [O] B Are vaccines stored in their original packages? Yes No [O] C Are there water bottles (for refrigerators) or frozen water bottles (for freezers) in the unit? Yes No [O] D Are vaccines store in the doors, vegetable bins, under or near cooling vents, Yes [O] or on the floor of the unit? No E Is food being stored in the unit? Yes [O] No Review CDC Recommendation: Vaccines should be stored in their original manufacturer (or CDC centralized distributor) packaging. They should be placed in the middle of the unit, with space between the vaccines and the side/back of the unit to allow cold air to circulate. Vaccines SHOULD NOT be stored in the doors, vegetable bins, or floor of the unit or under or near cooling vents and there should not be any food in the unit. Water bottles (for refrigerators) or frozen water bottles (for freezers) should be placed throughout each storage unit in order to: (1) stabilize or extend temperatures during a power outage and (2) to serve as physical blocks preventing the placement of vaccines in areas of the unit that are at higher risk for temperature excursions (such as in doors, vegetable bins, floor, or near/under cooling vents). Immediate Action: ☐ Assist provider with properly arranging vaccines in the unit. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 22 of 30 4. Storage & Handling Per Unit: Disconnection from Power Source Question 4.10: Note to Reviewer: Answers: (Choose all that apply) Ask the provider to demonstrate what measures are taken to ensure that vaccine storage units are not accidentally physically disconnected from the power supply. Which of the following describes the measure(s) taken on this unit? Large hospitals and healthcare systems may not have the ability to demonstrate labels on plugs or circuit breakers. In such cases, verify that the practice has a comprehensive policy and standard operating procedures in place to prevent the vaccine storage unit from being physically disconnected from the power supply. While back-up generators may ensure power to the overall facility, this question ONLY addresses the vaccine storage unit being accidentally disconnected from the power source either through the plug or the circuit breaker. A. “Do not disconnect” labels on the plug B. “Warning” label on the circuit breaker box C. Hard-wired (i.e. built-in) and has a “Do not disconnect” label on the circuit breaker box [X] The response is D. Hospital or large health care system with a comprehensive written policy non-compliant if only A, B, or and standard operating procedures detailing measures taken to prevent E is selected. vaccine storage units from being accidentally disconnected from the power supply E. No acceptable measures for preventing accidental disconnection from power supply [X] Review CDC Requirement: VFC providers must take steps to protect the power source for all vaccine storage equipment by means of having clear warning labels on both the plug and the circuit breaker associated with all vaccine storage units. Large hospitals and healthcare systems can meet this requirement by demonstrating that they have comprehensive policies and standard operating procedures to prevent vaccine storage units from being physically disconnected from the power supply. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Provide stickers or signs to place on electrical outlets and/or circuit breakers, as applicable. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 23 of 30 5. Storage & Handling Site-Wide: Discussion of Cost & Quantity of Vaccine Question 5.1: Note to Reviewer: Answer: Have a discussion with the provider about the cost and quantity of VFC vaccines they are responsible for annually. Address the points listed in the note to reviewer below. Vaccine Shipped (Required): Share the cost of VFC vaccines shipped to the provider in the last calendar year to make sure the provider understands the contribution made by the VFC Program to their practice. For new providers who do not have “calendar year” data, share either the actual cost of their current inventory or use the cost of 10 VFC doses of each of the ACIP-recommended vaccines (approximately $7,000) to help estimate their annual cost. Storage & Handling (Required): Make sure the provider understands the cost of vaccines for which they are responsible when they make decisions about purchasing recommended vaccine storage and temperature monitoring equipment. ☐ I have discussed with the provider the cost and quantity of vaccines ordered in the previous calendar year. 5. Storage & Handling Site-Wide: Dorm-Style Units Question 5.2: Having reviewed all storage units, determine whether the provider has any dorm-style units and answer the questions below. Note to Reviewer: A dormitory-style refrigerator is a unit that has both refrigerator and freezer compartments behind a single exterior door. Dorm-style units also have an evaporator plate (cooling coil), which is usually located inside an icemaker compartment (freezer) within the refrigerator. A Are there any dorm-style units at this provider site? ☐ Yes [X] ☐ No (Skip to question 5.3) B Does the provider have sufficient space in existing compliant vaccine storage units that maintain proper temperatures to store all vaccines without use of the dorm-style unit at any time? ☐ Yes ☐ No [X] Review CDC Requirement: Dorm- and bar-style units are prohibited for vaccine storage. Vaccines stored in dorm-style units are considered non-viable and must be returned to the centralized distributor. CDC recommends the following vaccine storage unit types (in order of preference): pharmaceutical grade stand-alone or combination units (preferred); household/commercial stand-alone units; household/commercial combination units using the refrigerator section only. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Question A: Quarantine and label vaccine “DO NOT USE.” Follow Immunization Program protocol for returning vaccines to the centralized distributor. Future Follow-up: ☐ Question B: Provider to submit in no later than one month: Documentation certifying that you have acquired additional vaccine storage that complies with all program requirements. Submit one week of complete temperature documentation for the unit(s) that will be used to replace the dorm-style unit. ☐ Question B: Reviewer within one week: Notify the Immunization Program to adjust vaccine order quantities for this provider until the provider is able to validate that they have sufficient space for vaccine storage. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 24 of 30 5. Storage & Handling Site-Wide: Storage Unit Space Availability Question 5.3: Does the provider have sufficient room across storage units to store current stock as well as any additional stock acquired during peak season without overcrowding? Answers: (Choose one) ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers must have sufficient storage space to accommodate vaccine stock at the busiest time of year without overcrowding. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ If a specific unit does not have sufficient storage space, a portion of the vaccine must be moved to a unit that: (1) maintains appropriate temperature; (2) has space available; and (3) contains a temperature monitoring device with a current, valid certificate of calibration testing. If necessary, vaccines can be stored off-site in accordance with the provider’s Emergency Vaccine Management Plan. ☐ Discuss possibility of ordering a new storage unit to accommodate stock throughout the year. Future Follow-up: ☐ Provider to submit in no later than one month: Documentation certifying that your office has sufficient storage space (without overcrowding) to support your patient population. Examples of possible documentation include changes in ordering amounts or frequency or proof of purchase of new unit. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 25 of 30 5. Storage & Handling Site-Wide: Expired Vaccines Question 5.4: Look in each unit: Are there expired vaccines in any of the vaccine storage units at this site? Answers: (Choose one) ☐ Yes [X] ☐ No Review CDC Requirement: Vaccines should be rotated weekly and when a new shipment comes in so that longer-dated vaccines are stored behind shorterdated vaccines. If vaccines expire, they can no longer be stored in the same storage unit with viable vaccines. They must be placed in a container or bag clearly labeled “Do not use” and separated from viable vaccines to prevent inadvertent use. Expired vaccine must be returned to the centralized distributor within six months of expiration. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Bag, label, and remove expired vaccine from the unit and follow Immunization Program protocol for returning vaccines to the centralized distributor. Contact MDH at 651-201-5522 for guidance. ☐ Educate the provider on how to properly rotate stock to prevent vaccines from expiring. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 26 of 30 5. Storage & Handling Site-Wide: Back-up Thermometer Question 5.5: Note to Reviewer: Answers: (Choose one) Does the provider have a readily available back-up thermometer with a current and valid certificate of calibration testing? “Readily available” means that the thermometer is available to perform twice-a-day monitoring for a unit as required. CDC recommends that the back-up thermometer be maintained on site. ☐ Yes ☐ No [X] Review CDC Requirement: VFC providers must have a readily available back-up thermometer (i.e. a thermometer not being used to monitor any other vaccine storage unit) with a current and valid certificate of calibration testing. CDC recommends that the back-up thermometer be stored on site at the VFC provider location. To avoid space issues and confusion resulting from differing temperature readings, the back-up thermometer should be stored outside of the storage unit until needed. To prevent the certificates of calibration testing of the primary and back-up thermometers from expiring at the same time, the date of calibration testing (or issue date) of the back-up thermometer should be different from the date of calibration testing (or issue date) of the primary thermometer. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Future Follow-up: ☐ Provider to submit in no later than one month: Either: (1) proof of purchase of a back-up thermometer and a copy of the current and valid certificate of calibration testing (preferable) OR (2) a clear plan for how to obtain a back-up thermometer when needed in order to meet the twice-a-day monitoring requirement. Notes: 5. Storage & Handling Site-Wide: Preparation of Vaccine Question 5.6: Note to Reviewer: Answers: (Choose all that apply) When does this provider prepare vaccine for administration to the patient? For mass vaccination clinics, if one type of vaccine is offered, providers may pre-draw up to 10 doses. If using pre-filled syringes, pre-drawing also means activating the syringe by removing the needle guard or attaching a needle. ☐ Prepare dose immediately before administration ☐ Pre-draw doses for upcoming patients (in a regular clinic/practice) [O] ☐ Pre-draw up to 10 doses (in a mass-vaccination clinic) ☐ Pre-draw more than 10 doses (in a mass-vaccination clinic) [O] ☐ Other: [O] Review CDC Recommendation: CDC recommends preparing vaccines immediately prior to administration in order to assure viability of vaccine and prevent vaccine wastage. Vaccines that are not administered immediately are at risk of exposure to temperatures outside of the required range, which can affect vaccine viability and, ultimately, can leave children unprotected against vaccine-preventable diseases. 2016 MnVFC Site Visit Questionnaire (May 2016) Page 27 of 30 6. Inventory: Inventory Comparison Question 6.1: Note to Reviewer: Answers: (Choose one) Visually inspect storage units to determine if existing supply of vaccines proportionately mirrors populations served. Choose the most accurate statement below. CDC recommends that providers maintain a four-week supply of inventory. For this question, do not take into account vaccine types that the provider does not order. Here simply make sure that, overall, the vaccines in the provider’s storage units are available in sufficient amounts to serve their patient population. ☐ The current vaccine inventory proportionately reflects the populations identified. ☐ Only public stock is insufficient [X] ☐ Only private stock is insufficient [X] ☐ Both public and private stock are insufficient [X] ☐ Site uses the replacement method but does not appear to have enough vaccine for their population [X] ☐ Other: [X] Review CDC Requirement: VFC providers must order and stock routine vaccines in accordance with their patient population in order to prevent missed vaccination opportunities. Having sufficient amounts of all stocks prevents the inadvertent use of VFC vaccines for non-VFC-eligible patients and vice versa. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Discuss with the provider alternatives for resolving the stock shortage and maintaining proper inventory. Determine whether the provider should adjust ordering. Future Follow-up: ☐ Provider to submit in no later than two weeks: Documentation verifying that there is sufficient public and private inventory (as applicable). ☐ Reviewer must, no later than one week, notify the Immunization Program to monitor provider orders to ensure that they have sufficient public stock. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 28 of 30 6. Inventory: ACIP-Recommended Vaccines Question 6.2: Does the provider offer all ACIP-recommended vaccines for the population they serve? Answers: (Choose one) ☐ Yes ☐ No [X] (Select vaccines not offered below) ☐ The provider offers all vaccines except varicella because direct ship of the vaccine is unavailable from the manufacturer ☐ DTaP ☐ Hepatitis A ☐ Hepatitis B ☐ HIB ☐ HPV ☐ Influenza ☐ Meningococcal ☐ MMR ☐ Pneumococcal ☐ Polio ☐ Rotavirus ☐ Tdap/Td ☐ Varicella Review CDC Requirement: VFC providers agree to comply with immunization schedules, dosages, and contraindications that are established by the Advisory Committee on Immunization Practices (ACIP) for the vaccines identified and agreed upon in the Provider Agreement UNLESS: In the VFC provider's medical judgment, and in accordance with accepted medical practice, the VFC provider deems such compliance to be medically inappropriate for the child; The particular requirements contradict state law, including laws pertaining to religious and other exemptions. The VFC program entitles children to the following vaccines: DTaP, Hepatitis A, Hepatitis B, HIB, HPV, Influenza, Meningococcal, MMR, Pneumococcal, Polio, Rotavirus, Tdap/Td and Varicella. VFC providers are also required to ensure that VFC-eligible children have access to non-routine vaccines as needed. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Immediate Action: ☐ Provide educational materials and resources on vaccines not currently being offered. Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 29 of 30 6. Inventory: Separation of Stock Question 6.3: Observe how the provider differentiates stock in each storage unit to answer the questions below. A Is it clear which vaccines belong to public stock and which belong to private stock? ☐ Yes ☐ No [X] ☐ Not applicable, replacement site B Is it clear which vaccines belong to VFC stock and which belong to UUAV stock? ☐ Yes ☐ No [X] ☐ Not applicable, replacement site ☐ Not applicable, not UUAV-enrolled site Review CDC Requirement: In order to ensure that VFC vaccines are only administered to VFC-eligible children, VFC providers that serve both VFC and non-VFCeligible children must maintain their vaccine inventories in such a way that they can clearly differentiate public stock from private stock as well as VFC from other public stock. Actions if Non-Compliant: Root Cause: Human Causes [Related to specific person] Select one root cause ☐ Personal beliefs/opinions and explain in the ☐ Does not understand rationale space provided. of requirement ☐ Lack of concern for compliance Organizational Causes [Related to organization as a whole] ☐ Competing job assignments/workload ☐ Lack of (or insufficient) staff to perform required duties ☐ Budget limitations (for purchase of required equipment) ☐ Lack of (or insufficient) training of staff ☐ Lack of (or insufficient) processes/protocols Explain: Future Follow-up: 6 months: Conduct a follow-up site visit to assess whether the provider can differentiate public stock from private stock and/or VFC stock from other public stock (if applicable). Notes: 2016 MnVFC Site Visit Questionnaire (May 2016) Page 30 of 30