Annual Vaccination Reporting Changes

Article 21-A of the New York State Public Health Law (PHL) requires certain Department of Health (DOH)-regulated entities to offer to provide or arrange for the influenza vaccine annually to all employees and residents. Article 21-A also requires the submission of an annual survey to the DOH, due on May 1 each year, reporting the number of employees and residents who did not receive the influenza vaccination during the past influenza season, and the number of residents who have and have not received the pneumococcal vaccination at any time.

While the law has not changed, the reporting aspect is being implemented differently this year.  LeadingAge NY spoke with the Bureau of Immunizations and has guidance for adult care facilities (ACFs), nursing homes, and adult day health care (ADHC) providers.

ACFs:  DOH reports that the Public Health Law Article 21-A requirements to document influenza and pneumococcal vaccine status and provide or arrange for influenza and pneumococcal vaccination remain in effect.  The reporting requirement for ACFs that do not have a facility or agency covered under the Flu Mask Regulations (that is, the home care component of an assisted living program) has been suspended at this time; facilities will be notified when the next report is due.  We are uncertain if or when this reporting will be required, but will notify members when we learn more.

Nursing Homes:  The deadline for completion of the Healthcare Personnel Influenza Vaccination Report is May 2, 2014, and can be accessed on the Health Commerce System (HCS). This year, the report requires submission of healthcare personnel data. Resident immunization information is now being gathered through MDS data and is not submitted in this report. Timely completion of this report will impact your facility’s 2014 DOH Quality Pool score.

ADHC:  ADHC programs are also required to submit the HCP Influenza Vaccination Report by Fri., May 2. Please note ADHC programs should enter personnel immunization data through HERDS and should not combine the ADHC report with the nursing home report. Nursing homes and ADHC programs must be reported separately, even if they share the same Permanent Facility Identifier (PFI).

This year, there is a separate drop-down box for ADHC personnel immunization data. According to DOH, there is a drop-down box listing the nursing home and a separate option, in capital letters, for the ADHC data. If your organization operates more than one ADHC program, there should be a drop-down box to report data for each program.

DOH also communicated to the Adult Day Health Care Council that ADHC programs are not required to submit registrant immunization data this year.  It is unclear at this point when or how registrant immunization records will be collected in the future.

Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, Elliott Frost, efrost@leadingageny.org; or Anne Hill, ahill@leadingageny.org. All can be reached at 518-867-8828.