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The Pandemic MOU: What It Means for NYS Pharmacies
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Many experts view future influenza pandemics as inevitable. Pharmacies are perfectly positioned to be a key line of defense. For that reason—building on a model from the CDC and the Association of State and Territorial Health Officials —the New York State Department of Health (NYSDOH) has adapted a memorandum of understanding, or MOU, that sets up the framework for pharmacies to play a front-line role in the fight against pandemics. Click on the FAQs below to find out more, or read the MOU itself.

 


Why do we need an MOU just for pandemics?

Two key factors make a separate MOU for pandemics necessary:

  1. Pandemic preparation is different from seasonal flu preparation. The sheer scope of a pandemic—multinational, even global—requires a coordinated large-scale response, versus other localized emergencies. Seasonal influenza typically peaks in the winter, while pandemics are less predictable. A pandemic vaccine regimen may also involve multiple doses, multiple products, and the addition of adjuvant.
  2. Better coordination between public health and pharmacies is needed. According to the Association of State and Territorial Health Officials (ASTHO), few state and local agencies have had formal agreements with pharmacies to improve pandemic response. New York State intends to build relationships that allow pharmacies to play a role in line with their capacity to immunize a significant proportion of the population.  

 

How will the MOU help?

The MOU:

  • Lays out a clear roadmap for pandemic response before a pandemic hits
  • Leverages the existing infrastructure of pharmacies across New York State to deliver vaccines where needed, when needed, faster and more efficiently
  • Involves pharmacies as valued partners in pandemic response
  • Empowers you to fulfill your core mission—serving patients—in a time of great need 

 

Who can participate?

All pharmacies in New York State—except New York City locations—may sign the MOU. The city health department will receive its own allotment of vaccine from the federal government.

 

What does the MOU roadmap look like?

When a pandemic breaks out:

  • The federal government works with manufacturers to produce vaccines.
  • The NYSDOH commissioner invokes the MOU.
  • MOU pharmacies decide whether to take part in the pandemic response. Those who answer “yes” sign the NYS Pandemic Vaccine Provider Agreement, or PVPA. (The MOU is not legally binding, but the PVPA is.)
  • Pharmacies estimate (and share with NYSDOH) the number of vaccines they can store and will administer.
  • Upon receipt of the vaccines from the federal government, NYSDOH allocates vaccine at least weekly. The number of doses allocated depends on a variety of conditions.
  • Pharmacies ensure the training, equipping, and updating of their authorized vaccine personnel to handle the pandemic response.
  • Pharmacies enter all vaccine data into the New York State Immunization Information System (NYSIIS).

 

What if I already have agreements for closed PODs?

You should sign an MOU even if you already have closed POD (point of dispensing) agreements with your county health department.  Closed POD agreements establish parameters for local response to emergencies that are generally limited in duration and scope.  While they may be used at the earliest stages of an influenza pandemic response, the MOU will be vital to assist NYSDOH in efficiently disseminating enough vaccine to immunize a far greater number of people.  This response will take longer than most local emergencies, so including all capable and willing immunizers in the MOU will accelerate the process.

 

What will I have to do as a community pharmacist?

  1. Prepare your people. There’s no need to enroll your authorized vaccine personnel with NYSDOH; your agreement to the MOU automatically does that. You do have to ensure they hold the proper licenses/certifications, follow the NYS Pandemic Vaccine Provider Agreement (PVPA) and official guidance, properly handle and store vaccine, use the New York State Immunization Information System (NYSIIS), and mix antigen with adjuvant as necessary, among other activities.
  2. Prepare information systems.  Data can be submitted to NYSIIS manually in the NYSDOH Health Commerce System or through data exchange. 
  3. Receive and distribute the allocated vaccine. If you have multiple locations, you can either receive the vaccine at your distribution depot—at  which point you become responsible for meting it out to your sites—or have it delivered directly to your immunizing pharmacy locations.
  4. Serve your patients before, during, and after vaccination. This includes medical screenings appropriate to the vaccination, provision of education materials and instructions as needed, and reporting of adverse reactions.
  5. Use NYSIIS to report vaccine usage weekly, maintain an inventory of non-administered doses (those wasted, expired, or shipped to other sites), document the dose of antigen and adjuvant administered and on hand by each site address, and assess the type and timing of prior vaccinations. Pharmacies with access to the Countermeasure Data Management System (CDMS) may use that for doses administered reporting.


What will NYSDOH do?

NYSDOH will manage all vaccine orders and allocate vaccine at least weekly. It will coordinate with local health departments, state pharmacy organizations like PSSNY, and the NYS Incident Command Structure and Emergency Operation Team. In its public face, NYSDOH will manage public information activities.

At the same time, the agency will focus a range of efforts that will assist pharmacies.  NYSDOH will disseminate information to providers and the public about the disease and vaccine availability.   Once the pandemic subsides, NYSDOH will coordinate the retrieval and disposal of unused vaccine.

 

Will we need non-patient specific orders?

Yes, and the usual rules apply. In order to administer the pandemic vaccine, each pharmacy must procure a non-patient specific order from a physician or nurse practitioner within its county or in an adjoining county. Pharmacies that operate in multiple counties may need to acquire multiple non-patient specific orders, depending on the geographic location of their sites. Non-patient specific orders can list either immunizing staff or the pharmacies whose employees are included in the order.

 

What about payment?

Pharmacies cannot charge for vaccine and ancillary supplies, since the federal government will provide them for free. They can, however, charge for the administration of the vaccine. This charge cannot exceed the regional Medicare vaccination administration fee or, if the fee is billed to Medicaid, the New York State Medicaid administration fee. Pharmacies are strongly encouraged—but not required—to vaccinate all who come to them, regardless of ability to pay. Federal funding may be available to pay administration fees for those who cannot afford them.

 

How do I find out more?