2016 MnVFC Provider Follow-up Plan Site: MnVFC PIN: Date of Visit: Thank you for participating in this MnVFC site visit. Please review the summary of your visit below. MnVFC requirements assessed during the visit that were “unmet” and require some follow-up have a checked box next to them. If you have any questions, please contact your site visit reviewer. Unmet ☐ Ques Q1.2 VFC Requirements – Section 1: Provider Details All changes in key staff must be communicated to the immunization program by emailing health.mnvfc@state.mn.us. Notes: All key staff must undergo annual training on VFC program requirements. Training must be documented. ☐ Required Action: ▪ Staff that have not taken the MnVFC online training on the MnVFC website (www.health.state.mn.us/vfc), must complete it and send the certificate to the IPI advisor. ▪ Due date: 1 month Notes: ☐ Q1.2 Unmet Ques VFC Requirements – Section 2: Eligibility Q2.1 Sites must possess a working knowledge of all VFC eligibility criteria and use those criteria to screen children prior to administering VFC vaccines. Notes: Q2.2 Sites must adhere to proper billing practices for vaccine administration fees and clearly understand VFC vaccine is provided at no cost both to the provider and eligible children. At no time should billing occur for the cost of VFC vaccine. ☐ Required Action: ▪ Submit in new or revised billing protocols addressing how your office will bill for each VFCeligible category ▪ Due date: 1 month Notes: Q2.3 The provider’s vaccine administration fee for non-Medicaid, VFC-eligible children must not exceed the vaccine administration fee cap established by the Centers for Medicare and Medicaid (CMS). In Minnesota, this is $21.22. VFC-eligible children must not be denied vaccine based on the patient’s inability to pay the vaccine administration fee. ☐ Required Action: ▪ Your site will receive a follow-up site visit to assess if this requirement is being met. ▪ Due date: 6 months Notes: ☐ ☐ ☐ IM M UNI ZA T IO N P RA CT I C E S IM PR OV EM E NT PR O GR AM ( IP I) (May 2016) Page 1 of 6 MNVFC PROVIDER FOLLOW-UP PLAN Unmet ☐ ☐ ☐ ☐ ☐ Ques VFC Requirements – Section 3: Documentation Q3.4 VFC providers must screen for and document VFC eligibility at each immunization visit. 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. ☐ Required Action: ▪ Submit new or revised protocols for conducting and documenting eligibility screening for each patient at each visit. ▪ Due date: 1 month Notes: Q3.5 Q3.6 Q3.7B Q3.7C 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. Notes: VFC providers are required to maintain all records related to the VFC program for a minimum of three years 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, records that verify receipt of vaccine, vaccine ordering records, and vaccine purchase and accountability records. ☐ Required Action: ▪ Submit a plan for maintaining historical patient eligibility documentation for a minimum of three years. ▪ Due date: 1 month Notes: VFC providers are expected to maintain an adequate inventory of vaccine for VFC and non-VFCeligible 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. All instances of borrowing must be properly documented. ☐ Required Action: ▪ Submit borrowing reports for the six months since the site visit. ▪ Due date: 6 months Notes: VFC providers are expected to maintain an adequate inventory of vaccine for VFC and non-VFCeligible 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. All instances of borrowing must be replaced. ☐ Required Action: ▪ Submit documentation of purchase of private stock used to replace borrowed doses. ▪ Due date: 1 month Notes: (May 2016) Page 2 of 6 MNVFC PROVIDER FOLLOW-UP PLAN Unmet ☐ ☐ Ques Q3.8 Q3.9 VFC Requirements – Section 3: Documentation VFC providers are expected to maintain an adequate inventory of vaccine for VFC and non-VFCeligible 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. ☐ Required Action: ▪ Submit new or revised protocols for managing vaccine ordering and inventory and other internal processes to prevent routine borrowing. ▪ Due date: 1 month Notes: VFC providers must develop, maintain and implement a Vaccine Management Plan for routine and emergency vaccine management. 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. ☐ Required Action: ▪ Submit an updated and complete Vaccine Management Plan. ▪ Due date: 1 month Notes: Q3.10 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. Notes: ☐ Q3.11 An anaphylaxis protocol must be clearly posted in the area where vaccines are administered. ☐ Required Action: ▪ Submit a complete anaphylaxis protocol. ▪ Due date: 1 month Notes: Unmet Ques VFC Requirements – Section 4: Storage & Handling per Unit Q4.3 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 = +/-0.5°C (+/-1°F). ☐ Required Action: ▪ Submit the following: (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. ▪ Due date: 1 month Notes: ☐ ☐ (May 2016) Page 3 of 6 MNVFC PROVIDER FOLLOW-UP PLAN Unmet ☐ ☐ ☐ ☐ Ques VFC Requirements – Section 4: Storage & Handling per Unit Q4.5 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 = +/-0.5°C (+/-1°F). ☐ Required Action: ▪ Submit a copy of the current and valid certificate of calibration testing for the temperature monitoring device in this section of the storage unit. ▪ Due date: 1 month Notes: Q4.6 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. Notes: Q4.7 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. ☐ Required Action: ▪ Submit complete temperature documentation of your temperatures over the next three weeks for this section of the storage unit. ▪ Due date: 1 month Notes: Q4.8 The site must document all excursions and actions taken including the following: (1) quarantine and label exposed vaccines, (2) place vaccine in a unit where it can be stored under proper conditions, (3) contact immunization program to report excursion, (4) contact the vaccine manufacturer to obtain documentation of vaccine potency. Notes: ☐ Q4.10 Unmet Ques ☐ Q5.2 Providers must take steps to protect the power source for all vaccine storage equipment by means of warning labels, back-up generators, and/or developing appropriate policies/protocols. Notes: VFC Requirements – Section 5: Storage & Handling Site Wide Dorm- and bar-style units are prohibited for vaccine storage. ☐ Required Action: ▪ Submit 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. ▪ Due date: 1 month Notes: (May 2016) Page 4 of 6 MNVFC PROVIDER FOLLOW-UP PLAN Unmet Ques VFC Requirements – Section 5: Storage & Handling Site Wide Q5.3 The site must have sufficient storage space to accommodate vaccine stock at the busiest time of year without crowding. ☐ Required Action: ▪ Submit documentation certifying that your office has sufficient storage space to support your patient population. Examples of possible documentation include changes in ordering amounts or frequency of proof of purchase of new unit. ▪ Due date: 1 month Notes: Q5.4 Vaccines should be rotated every week and when a new shipment comes in so that longer-dated vaccines are stored behind shorter-dated 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. Notes: ☐ Q5.5 VFC providers must have a readily available back-up thermometer with a current and valid certificate of calibration testing. ☐ Required Action: ▪ Submit 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 backup thermometer when needed in order to meet the twice-a-day monitoring requirement. ▪ Due date: 1 month Notes: Unmet Ques VFC Requirements – Section 6: Inventory Q6.1 VFC providers must order and stock routine vaccines in accordance with their patient population in order to prevent missed vaccination opportunities. ☐ Required Action: ▪ Submit documentation verifying that there is sufficient public and private inventory. ▪ Due date: 2 weeks Notes: Q6.2 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 or the particular requirements contradict state law, including laws pertaining to religious and other exemptions. Notes: ☐ ☐ ☐ ☐ ☐ Q6.3 Sites that serve both VFC and non-VFC-eligible children must maintain separate vaccine inventories that allow them to clearly differentiate public stock from private stock and allow them to differentiate VFC vaccines from other public stock. ☐ Required Action: ▪ Your site will receive a follow-up site visit to assess if this requirement is being met. ▪ Due date: 6 months Notes: (May 2016) Page 5 of 6 MNVFC PROVIDER FOLLOW-UP PLAN VFC Program Recommendations The following items provide additional information on current CDC recommendations. ▪ To assure viability of vaccines, providers should prepare vaccine immediately prior to administration. ▪ CDC storage unit recommendations are as follows: (1) pharmaceutical grade stand-alone or combination units (preferred); (2) household/commercial stand-alone units; (3) household/commercial combination units using the refrigerator section only. ▪ CDC recommends the use of a digital data logger thermometer with a detachable probe in a buffered material with continuous monitoring and recording capabilities. The temperature should be easily readable from the outside of the unit. ▪ Temperature probes should be buffered so that temperature monitoring devices measure the temperature of vaccine vials – not the temperature of the air in a storage unit. ▪ When selecting a data logger, CDC 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 ▪ Vaccines should be in their original packaging from the manufacturer and/or CDC centralized distributor and placed in the middle of the unit, with space both between the vaccines and the side/back of the unit. 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) serve as physical blocks preventing the placement of vaccines in areas of the unit that are at higher risk for temperature excursions. To be completed by the site visit reviewer I, (Site visit reviewer), acknowledge that a VFC site visit was performed on (visit date). A follow-up plan, which includes any issues identified (if applicable) was provided at the end of the visit. Site visit reviewer: Phone: Email: Reviewer Signature: Date: To be completed by the provider I, (Responsible Individual designated by MD), acknowledge that my practice took part in the VFC site visit noted above. I will communicate the plan and any follow-up items to the Medical Director. I understand the issues identified during the visit (if applicable) and agree to complete any required follow-up actions within the designated timeframe. Provider Signature: Date: (May 2016) Page 6 of 6