HHS Flexibility on Pharmacists Administering Childhood Vaccines: Factors to Consider

According to the Centers for Disease Control and Prevention (CDC), vaccination rates have fallen dramatically across the United States because of the COVID pandemic, particularly for children. In an effort to reverse the trend, the U.S. Department of Health and Human Services (HHS) announced in mid-August that it would allow pharmacists to administer vaccines to children 3-18 years, overriding existing state laws and regulations that otherwise prohibit it.

The pandemic has brought into clear focus the critical role that vaccinations play in protecting public health. Breadth of vaccination coverage is a key indicator of health system success, which is why decreasing vaccination rates are so alarming. The Gates Foundation noted that vaccination coverage internationally has dropped to levels not seen since the 1990s, setting us back “25 years in about 25 weeks.”

At a time when stay-at-home orders and fears of COVID-19 exposure have led many to put off wellness visits, improving childhood vaccination rates are a public health priority. Permitting pharmacists to administer vaccines can help close the gap, but the practice may carry an unintended consequence : a swift decline in essential preventive care visits. It should be weighed carefully.

According to the American Academy of Pediatrics, in-person wellness visits for children have declined significantly since the onset of the pandemic. The New York Times recently reported a 50 to 70 percent drop in pediatric visits  This results in children not only missing out on vaccinations but also failing to receive well-care screenings and physical and mental health preventive care – a driver for good health.,

For Community Health Centers in particular, there are a number of potential implications should this flexibility be permanently adopted. They include:

  • Chain drugstore pharmacists may not report vaccination data to health centers or the state’s vaccine registry unless required to do so, weakening coordination of care and leading to incomplete medical record at one’s “home” FQHC.
  • Chain drugstore pharmacists are not customarily trained to provide “whole person” care, which may lead to missed opportunities for other vital services, decreasing quality of care.

Changes in how these services are charged will lead to reimbursing health center practitioners at lower rates, while also negatively affecting  health center quality measure data and reporting to the Health Resources and Services Administration (HRSA)

These impacts deserve close consideration and attention. On the other hand, there are potentially significant benefits to this approach as well, including:

  • Pharmacists embedded into care teams have the potential to play a critical role in immunization care.
  • Pharmacists can screen, educate, and refer for immunizations since they are often the provider most often seen by patients.
  • Increasing the number of vaccinated children can decrease breakouts for diseases that are currently preventable through vaccines, decreasing the burden on health centers and the communities they serve.

The pandemic has forced America’s public health system to adapt and rethink how to deliver care over the course of the past few months. Each innovation may include risk or opportunity that remain important considerations for the public health community.. NACHC will continue to closely monitor this issue and stay connected with practitioners and health centers while they partner with local and state public health officials to improve pediatric vaccination and immunization rates.