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NACDS supports Vaccines Federal Implementation Plan

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ARLINGTON, Va. — On Tuesday, the National Association of Chain Drug Stores submitted comments to the Office of Infectious Disease and HIV/AIDS Policy (OIDP) in response to the draft Vaccines Federal Implementation Plan (VFIP) and in support of VFIP’s primary objective: to increase overall immunization rates across the nation by increasing accessibility of vaccinations to Americans and strengthening the vaccine infrastructure. 

NACDS said in the letter, “As committed partners in the effort to improve immunization rates in the U.S., we appreciate OIDP’s recognition throughout the Vaccines National Strategic Plan 2021-2025 (VNSP 2021-2025) and VFIP of the critical role community pharmacies and pharmacists play in expanding equitable access to vaccinations. 

“Specifically, [NACDS] support[s] and appreciate[s] the inclusion of pharmacies and pharmacists as outlined prominently in the VNSP, in addition to the VFIP’s recognition of the importance of pharmacists in addressing vaccine inequities and the promotion of vaccine confidence and acceptance; the critical role of pharmacies in enhancing access; the need to remove barriers to and incentivize vaccination in pharmacies; the effort to assess and seek to mitigate pharmacy barriers with respect to the Vaccines for Children (VFC) program; among others.” 

In 2019, NACDS submitted comments in response to the VNSP 2021-2025 Request for Information — which helped inform the current draft VFIP. NACDS’ recent comments draw from similar tenets outlined in the 2019 recommendations, yet also include recent experiences and learnings from pharmacies’ participation in the ongoing COVID-19 pandemic response. 

These recommendations build on the draft VFIP’s outlined strategies and actions to further foster equity and support public access to vaccination, including at pharmacies:  

  1. Collaborate with states to support scope of practice expansion for pharmacists and their staff, including pharmacy technicians, to administer all recommended vaccines across ages and states. 
  2. Support consistent coverage and reimbursement of pharmacy-based vaccines that cover pharmacies’ costs, vaccination administration, and counseling, including support for pharmacists as eligible providers in Medicare and Medicaid programs. 
  3. Coordinate with pharmacy stakeholders to mitigate undue barriers limiting the ability for pharmacies to participate in the VFC program. 
  4. Support the direct participation of pharmacies and pharmacists in value-based payment models.  
  5. Support the development of vaccine access programs for the uninsured at accessible care settings, including pharmacies. 
  6. Support bidirectional, interoperable Immunization Information Systems with standardized requirements across states that foster visibility and communication to and from all providers and settings of vaccine delivery, including pharmacies. 

The COVID-19 pandemic has further emphasized pharmacies’ effectiveness and value when it comes to enhancing equitable access to vaccinations and COVID-19-related care services across communities. According to government statistics: 

  • pharmacies have administered more than 234 million COVID-19 vaccinations to date; 
  • today, 2 of every 3 COVID-19 vaccine doses are provided at a pharmacy; 
  • more than 40% of those vaccinated at pharmacies were from racial and ethnic minority groups; 
  • more than 46% of children ages 5 to 11 who received a COVID-19 vaccination did so at a pharmacy; 
  • half of pharmacy COVID-19 vaccination sites are located in areas with high social vulnerability;
  • pharmacies have provided more than 11,000 mobile COVID-19 vaccination clinics across the country; 
  • pharmacies provide more than 20,000 COVID-19 testing sites nationwide, and 70% of such sites are in areas with moderate to severe social vulnerability; 
  • pharmacies and retail health clinics provide access to COVID-19 antivirals at thousands of locations nationwide. 

Pharmacies’ accessibility remains vital as the vaccination effort continues – and particularly given recent news that the U.S. Food and Drug Administration has authorized and the Centers for Disease Control and Prevention has recommended a second booster dose of COVID-19 vaccine for people over the age of 50 and certain immunocompromised individuals. 

At the same time, the COVID-19 pandemic has more broadly demonstrated the role of pharmacies in helping to break down access barriers by providing integrated healthcare destinations within the communities they serve. Even before the onset of the COVID-19 pandemic, pharmacies increasingly provided enhanced access to routine vaccinations, screening and testing for conditions including HIV and hepatitis C, chronic care management for diabetes and cardiovascular disease and support for behavioral health conditions, including mental health and substance use challenges. 

In fact, a new systematic review by the Centers for Disease Control and Prevention’s Community Preventive Services Task Force highlights the valuable role of pharmacies in advancing patient care and public health — and specifically underscores the value of pharmacy-based interventions and the resulting positive, cost-effective impact on cardiovascular disease prevention and management. 

More information about NACDS’ lessons and recommendations from the COVID-19 pandemic is available at 


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