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COVID-19 Vaccination Data Access and Strategies Used to Improve Immunization Rates (GAO-24-106526)

Summary

A GAO report to congressional requesters, GAO-24-106526, dated April 2024, on Medicaid and COVID-19 vaccination. It reports that six selected state Medicaid programs varied in their ability to obtain data on beneficiaries' COVID-19 vaccinations from state immunization information systems during the COVID-19 public health emergency from 2020-2023. It explains that these systems, maintained by state public health departments, were the primary source of such data during the emergency. The report also describes strategies the states used to improve immunization rates among Medicaid beneficiaries.

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                United States Government Accountability Office
                Report to Congressional Requesters




                MEDICAID
April 2024




                COVID-19 Vaccination
                Data Access and
                Strategies Used to
                Improve Immunization
                Rates




GAO-24-106526
                                                April 2024

                                                MEDICAID
                                                COVID-19 Vaccination Data Access and Strategies
                                                Used to Improve Immunization Rates
Highlights of GAO-24-106526, a report to
congressional requesters




Why GAO Did This Study                          What GAO Found
Given the importance of COVID-19                Six selected state Medicaid programs GAO reviewed varied in their ability to
vaccinations in preventing severe               obtain data on beneficiaries with COVID-19 vaccinations from state immunization
outcomes, such as hospitalizations and          information systems during the COVID-19 public health emergency from 2020-
death, ensuring Medicaid beneficiaries          2023. During the emergency, these systems—maintained by state public health
receive the vaccine is important.               departments—were the primary source of such data. This was because providers
However, state Medicaid programs did            administering COVID-19 vaccinations were required to report to them.
not always receive information on the           Specifically, state policies—which govern provider reporting requirements and
vaccination status of beneficiaries             data sharing—in effect prior to the emergency enabled Medicaid programs in four
directly from providers during the
                                                selected states to obtain patient-level vaccination data from state immunization
public health emergency. This was in
                                                information systems. In contrast, state policies in effect prior to the emergency in
part because vaccines were purchased
by the federal government rather than           two selected states either did not specify or did not permit such data exchange.
by insurers like Medicaid.                      COVID-19 Vaccination Data Collection and Transmission to Certain State Medicaid Programs
GAO was asked to examine Medicaid
programs’ access to and use of data
from immunization information systems
to improve COVID-19 vaccination rates
among beneficiaries, and factors
contributing to data completeness. This
report describes (1) the extent to which
selected states’ Medicaid programs
obtained patient-level COVID-19
vaccination data, and any factors               State officials and stakeholders described interoperability gaps between state
affecting data availability and quality;        immunization and Medicaid systems, the volume of vaccination data collected,
and (2) how that data helped inform             and other factors as affecting the availability and quality of COVID-19 vaccination
selected states’ strategies to improve          data collected by immunization information systems during the COVID-19 public
COVID-19 vaccination rates, and                 health emergency. State officials described how some factors resulted from the
information on the effectiveness of             public health emergency. They also noted solutions they implemented as the
such strategies.                                emergency progressed, such as using a temporary storage system for the
GAO reviewed relevant federal laws,             increased volume of data. State and federal officials also identified state policies
interviewed federal agency officials, as        as continuing to be important drivers of vaccination data collection and data
well as reviewed information and                sharing with Medicaid programs after the public health emergency.
interviewed officials from state public
                                                In the four selected states with access to patient-level data, GAO found that
health departments and Medicaid
                                                Medicaid programs used the data to implement two types of strategies to
programs in six states. The states were
selected based on characteristics of
                                                increase COVID-19 vaccination rates: incentives and targeted outreach. For
their Medicaid and immunization                 example, one state awarded incentive payments to its 25 managed care
programs, among other various                   organizations based on performance across 10 vaccination measures.
factors. GAO also interviewed 10                Additionally, Medicaid and managed care officials in five of the six states
stakeholder organizations, including            described using data from other sources, such as Medicaid claims, to increase
those representing immunization                 COVID-19 vaccination rates among high-risk and vulnerable populations. For
managers and Medicaid directors.                example, Medicaid officials in these states told us Medicaid claims data helped
                                                them to identify and focus efforts on beneficiaries most at risk of adverse
                                                outcomes from COVID-19. Although states reported using various strategies to
                                                increase vaccinations, the effectiveness of their specific strategies is unclear due
View GAO-24-106526. For more information,       to the nature of the COVID-19 public health emergency. According to Medicaid
contact Catina B. Latham at (202) 512-7114 or   officials, it is difficult to attribute changes in Medicaid beneficiaries’ vaccination
lathamc@gao.gov.                                rates to a specific strategy, because the emergency required multiple concurrent
                                                strategies.

                                                                                            United States Government Accountability Office
Contents


Letter                                                                                             1
                       Background                                                                  6
                       Selected States Varied in Obtaining COVID-19 Vaccination Data;
                         System Interoperability Among Factors that Affected Data
                         Availability and Quality                                                10
                       Selected States Used COVID-19 Vaccination and Other Data to
                         Inform Vaccination Incentives and Outreach Efforts, but
                         Effectiveness of Individual Strategies is Unclear                       22
                       Agency Comments                                                           30

Appendix I             Medicaid Program Changes to Support COVID-19 Vaccination
                       Activities                                                                31



Appendix II            Barriers to COVID-19 Vaccination and Strategies to Address Them           32



Appendix III           GAO Contact and Staff Acknowledgments                                     35



Related GAO Products                                                                             36


Tables
                       Table 1: Selected State Medicaid COVID-19 Vaccination Incentive
                               Programs for Managed Care Organizations                           23
                       Table 2: Examples of Medicaid Program Changes to Respond to
                               the COVID-19 Public Health Emergency                              31
                       Table 3: Examples of Strategies to Improve COVID-19
                               Vaccination Rates Used by Medicaid Programs in Six
                               Selected States                                                   33

Figures
                       Figure 1: Example of Routine Immunization Data Exchange with
                                Immunization Information Systems                                  8
                       Figure 2: COVID-19 Vaccination Data Exchange Scenarios                    12




                       Page i                        GAO-24-106526 Medicaid COVID-19 Vaccination Data
Abbreviations

CDC           Centers for Disease Control and Prevention
CMS           Centers for Medicare & Medicaid Services
HHS           Department of Health and Human Services



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Page ii                                GAO-24-106526 Medicaid COVID-19 Vaccination Data
                       Letter




441 G St. N.W.
Washington, DC 20548




                       April 18, 2024

                       The Honorable Ron Wyden
                       Chair
                       Committee on Finance
                       United States Senate

                       The Honorable Robert P. Casey, Jr.
                       Chairman
                       Special Committee on Aging
                       United States Senate

                       Vaccination efforts were a critical and complex part of the response to the
                       COVID-19 public health emergency. According to the Centers for Disease
                       Control and Prevention (CDC), an estimated 81 percent of the U.S.
                       population, or about 270 million people, received at least one dose of the
                       COVID-19 vaccination as of May 11, 2023. 1 Yet, the public health
                       emergency also highlighted disparities in vaccination rates among certain
                       populations, including low-income and medically needy populations with
                       health coverage provided by Medicaid, according to some sources. For
                       example, a December 2021 publication noted that estimated COVID-19
                       vaccination rates for Medicaid beneficiaries in some states averaged 15
                       percent to 20 percent lower than estimates for people enrolled with other




                       1On January 31, 2020, the Secretary of Health and Human Services declared a public
                       health emergency for the United States, retroactive to January 27, 2020, and ended the
                       public health emergency on May 11, 2023. The data represents CDC’s reporting of
                       COVID-19 vaccine administration for at least one dose of COVID-19 vaccine as of May
                       11, 2023. The CDC is an agency within the Department of Health and Human Services.



                       Page 1                                GAO-24-106526 Medicaid COVID-19 Vaccination Data
forms of health coverage. 2 Medicaid beneficiaries may have complex
needs that could lead to poorer health outcomes due to COVID-19. 3

Given the importance of COVID-19 vaccinations in preventing severe
outcomes, such as hospitalizations and deaths, ensuring that Medicaid
beneficiaries receive the vaccine is important. However, state Medicaid
programs did not always have information on the vaccination status of
their beneficiaries during the COVID-19 public health emergency. Health
insurance claims did not fully capture information on COVID-19
vaccinations administered. 4 This was, in part, because COVID-19
vaccinations were purchased and distributed by the federal government
free of charge during the COVID-19 public health emergency. 5

When vaccinations for COVID-19 became available in December 2020,
the federal government required providers administering them to report
relevant information, such as the individuals vaccinated, to immunization

2See Rebecca Cooper et al., “Strategies to Increase COVID-19 Vaccination Rates in
Medicaid Enrollees: Considerations for State Leaders,” The National Academy for State
Health Policy and Duke University, Margolis Center for Health Policy (2021). See also
Sandhya Raman, “Medicaid Beneficiaries Less Likely to Get COVID-19 Shots,” Roll Call,
(June 30, 2021); and Phil Galewitz, “Medicaid Vaccination Rates Founder as States
Struggle to Immunize Their Poorest Residents,” PBS (Sept. 2, 2021).
3For example, according to a December 2022 analysis by the Medicaid and CHIP
Payment and Access Commission, Medicaid beneficiaries are more likely to report having
certain conditions, such as asthma, compared to individuals with private insurance (18.6
percent and 13.8 percent, respectively), and having fair or poor health (24.1 percent
compared to 7.3 percent, respectively). See the Medicaid and CHIP Payment and Access
Commission, “MACStats: Medicaid and CHIP Data Book” (Washington, D.C.: December
2022).
4For example, using data as of June 4, 2021, the Centers for Medicare & Medicaid
Services (CMS) estimated the agency had a claim for about half of vaccinated Medicare
beneficiaries, noting that was because many providers had administered vaccinations free
of charge and did not submit claims to bill for that service. See Centers for Medicare &
Medicaid Services, “Assessing the Completeness Of Medicare Claims Data For
Measuring COVID-19 Vaccine Administration,” accessed January 11, 2024,
https://www.cms.gov/data-research/cms-covid-19-data-products/medicare-covid-19-vaccin
e-analysis. See also Karen L. Schneider et al., “Use of Immunization Information Systems
in Ascertainment of COVID-19 Vaccinations for Claims-Based Vaccine Safety and
Effectiveness Studies,” JAMA Network Open, vol. 6, no. 5 (2023).
5CDC’s COVID-19 Vaccination Program ended as of October 3, 2023. However, most
Medicaid beneficiaries continue to be eligible for the COVID-19 vaccination free of cost
sharing. For example, Medicaid programs are required to cover and pay for COVID-19
vaccinations through September 30, 2024. Additionally, as of October 1, 2023, Medicaid
programs are required to cover and pay for all vaccinations recommended by the Advisory
Committee on Immunization Practices for most adult Medicaid beneficiaries, which
includes the COVID-19 vaccination.




Page 2                                GAO-24-106526 Medicaid COVID-19 Vaccination Data
information systems. As a result, immunization information systems
became a primary source of data for tracking COVID-19 vaccination rates
and vaccination rate disparities—including among Medicaid
beneficiaries—and for directing resources to help increase vaccination
rates. 6 These immunization information systems are primarily operated by
states, with support from CDC, and their capabilities and data vary for a
variety of reasons, including differences in state laws. 7 Prior to the
COVID-19 public health emergency, immunization information systems
helped states and other entities track vaccination coverage in order to
identify populations at risk of acquiring vaccine-preventable diseases,
such as measles or influenza, and to respond to outbreaks. The scale of
the COVID-19 vaccination effort highlighted existing challenges with
immunization information systems, as well as questions about the
completeness of the COVID-19 vaccination data they received. 8

You asked us to examine Medicaid programs’ access to and use of data
from immunization information systems to improve COVID-19 vaccination
rates among beneficiaries, and factors contributing to immunization data
completeness. In this report we describe

1. the extent to which selected states’ Medicaid programs obtained
   COVID-19 vaccination data through immunization information
   systems, and any factors that affected data availability and quality;
   and
2. how data from immunization information systems helped inform
   strategies by selected states’ Medicaid programs to improve COVID-
   19 vaccination rates, and information on the effectiveness of such
   strategies.
To describe the extent to which selected states’ Medicaid programs
obtained COVID-19 vaccination data through immunization information
systems, and which factors affected data availability and quality, we

6As of October 6, 2023, when COVID-19 vaccinations became available for purchase on
the commercial market, CDC could no longer require providers to report COVID-19
vaccination administration information to immunization information systems.
7For example, according to the National Council of State Legislatures, 25 of 60 state and
other jurisdictions (e.g., territories that submitted their policies to CDC) require that all
providers report adult immunizations, and 28 jurisdictions have a reporting requirement in
place that may vary based on vaccine provider, age of patient, type of vaccine or specific
circumstance, such as a declared public health emergency.
8See Congressional Research Service, Immunization Information System: Overview and
Current Issues (Washington, D.C.: Feb. 1, 2022).




Page 3                                   GAO-24-106526 Medicaid COVID-19 Vaccination Data
reviewed relevant laws, regulations, and guidance. This included CDC
guidance on immunization information systems and requirements for
reporting COVID-19 vaccination data. We interviewed officials from CDC
and the Centers for Medicare & Medicaid Services (CMS) regarding
efforts supporting COVID-19 vaccination data sharing between Medicaid
and public health entities, as well as vaccination data quality. 9 We also
reviewed documentation and conducted interviews with Medicaid and
public health officials in a non-generalizable sample of six states
(California, Connecticut, Georgia, Idaho, Maryland, and Michigan).

We selected the non-generalizable sample of six states based on
variation across several criteria, including

•   the share of adults residing in the state captured in the immunization
    information system as of December 2020 and 2021, as a proxy for
    data availability, based on CDC’s Immunization Information System
    Annual Report;
•   state per-capita COVID-19 vaccination rates showing the proportion of
    individuals who had completed a vaccination series as of March 29,
    2023, from CDC’s COVID-19 Data Tracker; and
•   whether state immunization information systems shared data with
    their Medicaid programs, as reported by the Association of
    Immunization Managers’ 2019 Annual Survey. 10
In selecting states, we also considered variation in different Medicaid
program characteristics that could affect state Medicaid programs’
experiences using data. These characteristics included the state’s service
delivery model (i.e., managed care or fee-for-service), Medicaid
enrollment size, racial and ethnic distribution of the non-elderly Medicaid
population, and Medicaid expansion status. 11


9CMS is an agency within the Department of Health and Human Services.

10The Association of Immunization Managers’ survey captures responses from state
immunization program managers on “whether the immunization information system and
Medicaid share data and/or Medicaid uses the immunization information system for
reporting,” but does not describe the type or frequency of sharing that occurs.
11States may provide Medicaid services under a managed care model, a fee-for-service
model, or both. Under managed care, states pay managed care plans capitation
payments, which are fixed periodic payments typically paid on a per enrolled Medicaid
beneficiary basis. In turn, the managed care plans are responsible for paying providers for
the services delivered to enrolled beneficiaries. Under fee-for-service, states make
payments directly to providers for services provided.




Page 4                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
In each of the six states, we reviewed relevant state laws and data use
agreements, and interviewed state public health and Medicaid officials to
understand the collection and sharing of immunization data before,
during, and after the COVID-19 public health emergency. We also
interviewed state public health and Medicaid officials regarding factors
affecting immunization data collection, data sharing, and data quality. We
also interviewed the health information exchange organization in
Maryland, as it played a role in the exchange of immunization data
between the state’s immunization information system and its Medicaid
program. 12 In addition, we interviewed officials at the Department of
Health and Human Services’ (HHS) Office of the National Coordinator for
Health Information Technology to understand federal efforts related to
data sharing, such as interoperability between immunization information
systems and other health systems. We also interviewed officials from a
non-generalizable sample of 10 stakeholder organizations, and reviewed
reports, surveys, and fact sheets they developed. 13

To describe how data from immunization information systems helped
inform strategies selected states’ Medicaid programs used to improve
COVID-19 vaccination rates, and information on the effectiveness of such
strategies, we reviewed relevant federal guidance and state policies. For
example, we reviewed CMS guidance describing flexibilities available to
state Medicaid programs to respond to the COVID-19 public health
emergency and strategies for increasing COVID-19 vaccination rates




12Health information exchange organizations are organizations that electronically move
data among health care stakeholders, such as laboratories, public health departments,
hospitals, and physicians. Some states have one or more health information exchange
organizations that facilitate health information exchange statewide or for specific areas of
a state. A health information exchange organization may also facilitate exchange for
multiple states in a region of the country.
13We interviewed officials from the following stakeholder organizations: AcademyHealth,
American Immunization Registry Association, Association of Immunization Managers, the
Association of State and Territorial Health Officials, Civitas Networks for Health, Duke
Margolis Center for Health Policy, Medicaid and CHIP Payment and Access Commission,
National Association for State Health Policy, National Association of County and City
Health Officials, and the National Association of Medicaid Directors. We selected these
organizations due to their familiarity with immunization information systems, vaccination
data sharing between Medicaid and public health agencies, vaccination strategies, or
because they had published research in this area. When characterizing the responses
made by these organizations, we used the term “some” when mentioned by fewer than
five stakeholders.




Page 5                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
             among the general population, including Medicaid beneficiaries. 14 We
             also reviewed CDC guidance on barriers to vaccination and strategies for
             increasing access to and receipt of recommended vaccinations, including
             among vulnerable populations. 15 We also reviewed relevant state policies
             and other documentation, and interviewed Medicaid officials in the six
             selected states about the strategies they used to increase COVID-19
             vaccination rates, including among vulnerable and high-risk populations,
             and information on their effectiveness. We also reviewed documentation
             and interviewed officials from the largest Medicaid managed care
             organization, based on enrollment, in the four selected states with this
             type of delivery system (California, Georgia, Maryland, and Michigan), as
             well as officials with Connecticut’s medical administrative services
             organization, which provides administrative services to support the state
             Medicaid program in processing provider claims. Also, to better
             understand strategies to improve COVID-19 vaccination rates and their
             effectiveness, we interviewed officials from 10 stakeholder organizations,
             and reviewed articles identified from a search of various databases such
             as Scopus, ProQuest Health & Medical Collection, MEDLINE, and
             ProQuest COVID-19 Research. 16

             We conducted this performance audit from January 2023 to April 2024 in
             accordance with generally accepted government auditing standards.
             Those standards require that we plan and perform the audit to obtain
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.

             Immunization information systems play a vital role in public health
Background   officials’ efforts to monitor vaccination coverage for routine vaccinations
             and to identify areas of low vaccination, which may be more likely to

             14See appendix I for information on flexibilities that were available to state Medicaid
             programs during the public health emergency to support them in their efforts to ensure
             beneficiaries had access to COVID-19 vaccinations.
             15See appendix II for information on barriers to COVID-19 vaccination and strategies for
             addressing them, including strategies used by the six selected state Medicaid programs to
             increase vaccination rates that were not informed by data from immunization information
             systems.
             16Our literature search covered scholarly articles, conference papers, government reports,
             and non-profit materials published from 2020 to 2023. Through this review, we identified
             12 articles that contained information on barriers and strategies to improve COVID-19
             vaccination rates more broadly.




             Page 6                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
experience outbreaks of vaccine-preventable diseases, such as measles
and influenza. Immunization information systems collect a variety of
information on vaccines administered, such as the name and date of birth
for individuals who received a vaccine, and the type of vaccination
administered. State public health departments initially developed
immunization information systems to capture routine childhood
vaccinations, but many states use them to collect information on
vaccinations administered to adults as well. 17

In general, state policies govern provider reporting requirements and data
sharing, and those policies vary by state. 18 For instance, state policies
may vary in terms of the type of providers required to report immunization
data, and in the consent policies that allow immunization information
systems to collect and store patients’ vaccination records. 19 In addition,
state policies may determine whether immunization information systems
share or exchange patient-level data—that is, the individual immunization
records recorded for each patient that contain identifiable demographic
information—with other entities, including other jurisdictions or state
agencies.

Specifically, depending on the state, immunization information systems
may share patient-level vaccination data with




17For example, as of 2020, these systems were estimated to capture immunization data
for 68 percent of adults, nationally, compared to 84 percent of 11- to 17-year-olds, and 94
percent of less than 6-year-olds. See Centers for Disease Control and Prevention, “2020
IISAR Data Participation Rates,” accessed January 29, 2024,
https://archive.cdc.gov/#/details?url=https://www.cdc.gov/vaccines/programs/iis/annual-re
port-iisar/2020-data.html. More recent estimates indicate increases in the percentage of
adults captured in immunization information systems since the start of the COVID-19
public health emergency. For example, adult participation data as of 2022 indicate
immunization data are captured for 94 percent of adults, nationally.
18COVID-19 vaccination reporting differed substantially during the public health
emergency. Specifically, to be permitted to administer the COVID-19 vaccination through
CDC’s COVID-19 Vaccination Program, CDC required providers to report information
about vaccinated individuals. Additionally, similar to routine immunization data, CDC
encouraged providers to report demographic information about vaccinated individuals,
such as race and ethnicity, to immunization information systems to assist with vaccination
monitoring efforts during the COVID-19 public health emergency.
19According to stakeholders and for the purposes of this report, state patient consent
policies are policies in certain states that may allow patients the right to opt-out of or opt-in
to sharing their vaccination data with the immunization system (i.e., remove or exclude
vaccination data in the immunization information system).




Page 7                                    GAO-24-106526 Medicaid COVID-19 Vaccination Data
                                       •   providers to help them ensure that their patients are up-to-date on
                                           their vaccinations,
                                       •   patients to help them manage their health care, and
                                       •   health plans or state Medicaid agencies to help support quality
                                           improvement efforts. 20
                                       In situations where identifiable data are not necessary or permitted to be
                                       shared, immunization information systems may instead share de-
                                       identified or aggregate data, such as the vaccination rate for a given area
                                       or population. This type of data may be reported to CDC or included as
                                       part of public data dashboards to support routine vaccination efforts or
                                       disease surveillance activities, as was the case during the COVID-19
                                       public health emergency. (See fig. 1.)

Figure 1: Example of Routine Immunization Data Exchange with Immunization Information Systems




                                       20As part of its responsibility to oversee states’ efforts to ensure the quality of services
                                       provided to Medicaid beneficiaries, CMS collects, assesses, and reports on standardized
                                       measures of quality of care. CMS does this primarily through the Child and Adult Core
                                       Sets, which include quality measures related to primary and preventive care, behavioral
                                       health care, and patients’ experiences of care. For example, states may report on the
                                       percentage of children in the Medicaid program that are up-to-date on their immunizations.
                                       States report measure results to CMS annually, and while state reporting had been
                                       voluntary, reporting for most measures became mandatory in fiscal year 2024.




                                       Page 8                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
Although states are responsible for maintaining their immunization
information systems, CDC provides funding and technical assistance to
support system infrastructure, data storage and sharing, as well as
workforce support. 21 CDC also develops functional standards for the
various operations, data quality, and technological capabilities for
immunization information systems. CDC encourages states to adopt the
functional standards, but states can implement or customize them. For
example, CDC’s functional standards suggest that immunization
information systems be capable of sharing data with other health
systems, but a state has flexibility in determining how to implement data
sharing. 22 CDC also encourages, but does not require, states to collect
certain data elements in their immunization information systems, such as
race or ethnicity when reporting routine vaccination data.




21While CDC does not have a dedicated source of funding for immunization information
systems, the following CDC programs and cooperative agreements, among others, can be
used to support immunization information systems: the Epidemiology and Laboratory
Capacity for Prevention and Control of Emerging Infectious Diseases Program, Section
317 Immunization Program funding, and the Vaccines for Children Program. During the
COVID-19 public health emergency, CDC provided $3 billion in supplemental funding to
support various vaccination-related activities, including expanding the existing
immunization information system infrastructure.
22For instance, a state may choose to implement one-way sharing, which allows the
immunization information system only to receive vaccination data, or two-way (i.e.,
bidirectional) sharing, which also allows the immunization information system to send as
well as receive vaccination data from the other organization.




Page 9                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
Selected States
Varied in Obtaining
COVID-19
Vaccination Data;
System
Interoperability
Among Factors that
Affected Data
Availability and
Quality
Four of Six Selected        Medicaid programs in our six selected states varied in their ability to
States’ Medicaid Programs   obtain patient-level COVID-19 vaccination data from state immunization
                            information systems. Specifically, the Medicaid programs in four of the six
Obtained Patient-Level
                            states (California, Georgia, Maryland, and Michigan) obtained patient-
COVID-19 Vaccination        level COVID-19 vaccination data from their state immunization
Data from Immunization      information systems during the public health emergency. Prior to the
Information Systems         COVID-19 public health emergency, officials in these four states reported
During the Public Health    having laws that authorized their Medicaid programs to obtain
                            immunization data from the public health department.
Emergency
                            In addition, the processes for exchanging patient-level COVID-19
                            vaccination data between immunization information systems and the
                            Medicaid programs varied among the four states. (See fig. 2.) For
                            example, in Maryland, the state health information exchange organization
                            helped facilitate the exchange, while in California and Michigan these
                            organizations were not part of the process. 23 Specifically, Maryland’s
                            health information exchange organization gathered and compiled data
                            from different sources, such as hospitals, Medicaid, and the immunization
                            information system, into a database that the state public health
                            department and Medicaid could query to retrieve information on the
                            vaccination status of certain individuals. Additionally, the four states

                            23While Georgia’s health information exchange organization did not facilitate the
                            exchange of COVID-19 vaccination data between the state public health department and
                            Medicaid, Georgia Medicaid officials told us the health information exchange organization
                            shared any hospital or provider records that contained data related to COVID-19 with both
                            departments to help them to supplement their records.




                            Page 10                                GAO-24-106526 Medicaid COVID-19 Vaccination Data
varied in whether the Medicaid program had the ability to query
immunization data directly or needed assistance from the state public
health department in order to match beneficiary files with data from the
immunization information system. For example:

•   California public health officials told us the state Medicaid program
    provided their department with files listing Medicaid beneficiaries,
    which public health officials then matched to immunization data from
    their own system before sending files back with immunization records
    added.
•   Georgia Medicaid officials told us the state public health department
    provided the state Medicaid program files containing all immunization
    records, which they then matched to Medicaid beneficiary records.
•   Maryland and Michigan officials told us they were able to identify
    Medicaid beneficiaries’ immunization records in a repository that
    merged data from the immunization information system and other
    data sources operated by the health information exchange
    organization or the state health department, respectively.




Page 11                         GAO-24-106526 Medicaid COVID-19 Vaccination Data
Figure 2: COVID-19 Vaccination Data Exchange Scenarios




                                       Note: This figure depicts two examples of the exchange of COVID-19 vaccination data exchange
                                       between state immunization information systems and Medicaid programs during the COVID-19 public
                                       health emergency.




                                       Page 12                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
Medicaid or public health officials from California, Georgia, and Maryland
also noted their Medicaid programs and state public health departments
exchanged COVID-19 vaccination data more often than they had
exchanged routine vaccination data prior to the COVID-19 public health
emergency. For example, Medicaid and public health officials from
Georgia and Maryland said they shared COVID-19 data weekly, while
they shared routine vaccination (e.g., influenza, measles) data less
frequently or as needed. 24

In contrast, Medicaid programs in the remaining two selected states
(Connecticut and Idaho) did not obtain patient-level COVID-19
vaccination data from their state immunization information systems.

•   In Connecticut, state Medicaid and public health officials said the state
    regulation in effect prior to the COVID-19 public health emergency did
    not specify Medicaid as an authorized user; thus, the Medicaid
    program did not obtain vaccination data from the immunization
    information system. Although a new state law enacted in July 2022
    expanded the types of entities explicitly permitted access to
    immunization data, Medicaid and state public health officials told us
    the issue of Medicaid’s access to the data was not resolved by the
    end of the COVID-19 public health emergency. 25
•   In Idaho, Medicaid officials told us that by state law their agency did
    not have access to patient-level vaccination data, but obtained
    aggregate COVID-19 vaccination data for adults from the
    immunization information system. 26 Using these data, Medicaid
    officials told us they were able to assess the extent to which Medicaid
    claims data reflected vaccination information for beneficiaries. As a
    result, they told us they were confident that Medicaid claims data


24Routine vaccinations are those recommended for adults, adolescents, and children in
the United States, depending on age and vaccine history. Routine vaccinations could
include vaccines for influenza, measles, mumps, or other vaccine preventable diseases.
25Because of the change to Connecticut law, public health officials told us they were
working to amend their data use agreement to enable them to share patient-level
vaccination data with the Medicaid program. See Connecticut House Bill 5506 § 493, Pub.
Act No. 22-118 (2022); CONN. GEN. STAT. ANN. § 19a-25 (2022).
26According to public health officials, Idaho state law does not allow the sharing of patient-
level vaccination data for children from the immunization information system, including
with the Medicaid program. The statute prohibits sharing patient-level information about
children with any entity not named in statute. Aggregate data for children can be provided
and de-identified information may be shared for adults 18 years and older. See ID. CODE
ANN. § 39-4803 (2023).




Page 13                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
                                accurately reflected information on vaccinated and unvaccinated adult
                                beneficiaries during the COVID-19 public health emergency.


Selected States and         State officials and stakeholders we interviewed described factors that
Stakeholders Described      affected the availability and quality of COVID-19 vaccination data during
                            the public health emergency, including for Medicaid programs. These
How Interoperability Gaps
                            factors had the potential to make the vaccination data Medicaid programs
and Other Factors           received from immunization information systems less usable or reliable
Affected COVID-19           when integrated into their data. Public health officials in some of the six
Vaccination Data            selected states also provided examples of how they addressed
Availability and Quality,   challenges as the COVID-19 public health emergency progressed.
Including for Medicaid      Interoperability gaps between systems. State Medicaid and public
Programs                    health officials from three of the four selected states that exchanged
                            COVID-19 vaccination data between Medicaid and their state
                            immunization information system (California, Georgia, and Michigan)
                            indicated that gaps in interoperability between older immunization
                            information systems and Medicaid systems affected the availability of
                            timely and complete vaccination data. 27 Furthermore, according to some
                            selected stakeholders, such as the American Immunization Registry
                            Association and the Association of Immunization Managers, challenges in
                            capturing COVID-19 vaccination data highlighted longstanding concerns
                            about interoperability and data sharing between aging immunization
                            information systems and other data systems. 28

                            Public health or Medicaid officials from three states (California, Georgia,
                            and Michigan) told us they had difficulty merging information from
                            Medicaid and public health sources, in part, because there are very few
                            data fields that are collected by both immunization information systems
                            and Medicaid programs due to the different needs of each program. For
                            27Conversely, Maryland officials told us that they did not have difficulty merging
                            information from Medicaid and public health sources because the state health information
                            exchange had the capability to consolidate data from different sources.
                            28See American Immunization Registry Association, Talking Points for IIS Regarding
                            COVID-19 Data Quality (Washington, D.C.: Feb. 19, 2021); and Association of
                            Immunization Managers, Collaborating with Medicaid: Immunization Programs
                            Observations (Rockville, Md.: July 30, 2021). Our prior work has also highlighted similar
                            challenges and concerns around interoperability in health information technology systems.
                            In June 2022, we reported state public health officials most often identified gaps in
                            interoperability among state systems as one of their top challenges related to the
                            management of public health information during the public health emergency. See GAO,
                            COVID-19: Pandemic Lessons Highlight Need for Public Health Situational Awareness
                            Network, GAO-22-104600 (Washington, D.C.: June 23, 2022).




                            Page 14                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
                                                  example, immunization information systems generally track vaccination
                                                  coverage and outbreak surveillance; however, Medicaid systems are
                                                  used to manage Medicaid patients’ care and bill for services. Public
                                                  health officials in Michigan told us that their inability to automate the
                                                  process of merging Medicaid and public health data meant staff manually
                                                  conducted data pulls, shared data, and matched patient records, which
                                                  increased the burden on staff and led to human error.

Medicaid Enterprise Systems Funding               Moreover, they noted that COVID-19 supplemental funding from CDC
Centers for Medicare & Medicaid Services’         supported upkeep of the state’s aging immunization information system,
(CMS) Medicaid Enterprise Systems funding         but did not enable them to fully modernize it.
may be used to support state Medicaid
programs’ information technology systems.
This funding is available for a range of          To counter interoperability challenges and improve data access, state
technology-related system activities, including
developing and implementing technology            public health and state Medicaid officials in these three selected states
supporting immunization information systems,      described using data use agreements to outline the formats for
as well as the maintenance and operations of      exchanging data. These data use agreements specifically outline the data
these systems.
Specifically, state Medicaid programs may
                                                  elements that are exchanged and the formats for doing so. Additionally,
request approval to receive an enhanced           public health officials in California shared that they planned to seek CMS
federal matching rate of 90 percent (i.e., $90    Medicaid Enterprise System funding to help improve their ability to match
in federal funds for every $10 spent by the
state) for the design, development, and           immunization information system data with Medicaid records in the future
implementation of their proposed project. To      and are considering a unique Medicaid identifier to improve their ability to
obtain approval, CMS requires states to
submit planning documentation that outlines
                                                  match data between Medicaid and public health systems. 29
project goals and an implementation timeline.
According to CMS officials, these plans
undergo a review to determine if the projects
                                                  Public health officials in our selected states also described varying
meet specific criteria—such as, seamless          degrees of participation in CDC’s Immunization Gateway during the
coordination and integration between              COVID-19 public health emergency. CDC developed the Immunization
systems—and will demonstrate measurable
outcomes and improvements to the state            Gateway—a data system intended to facilitate vaccination data exchange
Medicaid program. State Medicaid programs         both among states and between federal agencies (e.g., Department of
may also request a 75 percent enhanced
matching rate to support ongoing operations
                                                  Veterans Affairs) and states—in part to help address interoperability
of CMS-approved systems.                          challenges related to the exchange of information across these different
Source: CMS documentation. | GAO-24-106526



                                                  29In addition to Medicaid Enterprise System funding, Helios—a jointly funded effort by
                                                  CDC and the Office of the National Coordinator for Health Information Technology to use
                                                  data exchange standards to promote more flexible and effective data exchanges between
                                                  public health departments and other entities—may make it easier to leverage and share
                                                  vaccination data in immunization information systems. According to CDC officials, as the
                                                  standards developed through Helios mature, state Medicaid programs, where permitted,
                                                  will have access to modern methods for receiving the immunization histories of their
                                                  covered patients. In addition to Helios, CDC officials said they continue to support efforts
                                                  to improve the quality and completeness of vaccination data collected in immunization
                                                  information systems. According to CDC’s congressional budget justification for fiscal year
                                                  2024, the agency requested $1.2 billion to support its Immunization and Respiratory
                                                  Diseases Program to fund several activities, including continued efforts to modernize
                                                  immunization information systems.




                                                  Page 15                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
systems. 30 Three states (Connecticut, Maryland, and Michigan) used the
Immunization Gateway to exchange immunization data with some other
states during the COVID-19 public health emergency, but also used other
state-to-state data sharing arrangements, according to state public health
officials. 31 For example, Maryland officials reported they established a
connection through the Immunization Gateway with the District of
Columbia, which allowed them to add information to the state
immunization information system on more than 225,000 COVID-19 doses
administered to Maryland residents. The remaining three selected states
(California, Georgia, and Idaho) either did not exchange data with other
states using the Immunization Gateway during the COVID-19 public
health emergency or could not exchange immunization data with other
states due to state level policies restricting such exchange. 32

Patient matching. In three of the four selected states that exchanged
patient-level vaccination data (Georgia, Maryland, and Michigan) between
their state immunization information system and Medicaid, Medicaid and
public health officials identified challenges matching patient vaccination
records with Medicaid records, which is necessary to determine if the




30For example, when a patient crosses jurisdictional borders to receive a vaccination, their
vaccination record is reported to the state where the vaccine was administered. Unless
the record is subsequently shared with and integrated into the patient’s home state’s
immunization information system, that state will have missing data, as would any
downstream users of the data, such as Medicaid.
According to CDC officials, as of February 2023, most jurisdictions with immunization
information systems planned to participate in the Immunization Gateway, which became
operational in October 2021, with almost half having exchanged data with at least one
other immunization information system.
31In Connecticut, state public health officials told us that although the ability to share data
with the Medicaid program was unclear, state law in effect prior to May 2022 permitted the
state immunization information system to share data with federal partners and other
states’ immunization information systems. Thus, according to officials, data sharing
through the Immunization Gateway was also permitted.
32Five of the six selected states also reported using the Immunization Gateway to obtain
immunization data from the Department of Veterans Affairs during some of the COVID-19
public health emergency. States began exchanging through the Immunization Gateway at
different times with different entities. Establishing a connection through the Immunization
Gateway can take time and resources, according to public health officials in two selected
states. Michigan officials reported other barriers to fully utilizing the Immunization
Gateway, including earlier during the public health emergency, such as the readiness of
other states to connect to it.




Page 16                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
records refer to the same patient. 33 According to Georgia Medicaid
officials, patient matching errors meant that the program lacked
information on some Medicaid patients’ COVID-19 vaccinations, so
vaccination rates appeared lower than they were. Public health officials in
Michigan said that the COVID-19 vaccine rollout caused an
unprecedented number of duplicate records in Michigan’s immunization
information system, which they were able to resolve. Additionally, officials
noted they have multiple ongoing data modernization efforts that include
updates to the algorithms and processes they use to conduct patient
matching, which will further improve accuracy and data quality. 34

Volume of data. The increase in reporting volume associated with the
COVID-19 public health emergency overwhelmed the capacity of
immunization information systems to capture vaccination records when
COVID-19 vaccines first became available, according to public health
officials in two selected states (California and Idaho) and some
stakeholders we interviewed. For example, public health officials in
California noted they went from receiving up to 800,000 messages daily—
that is, vaccination records and queries requesting an individual’s
vaccination status—before the COVID-19 public health emergency to 4
million such messages during the public health emergency. According to
the officials, the outdated immunization information system was initially
unable to capture and store the large volume of vaccination data
received. As a result, the state stored vaccination data in a cloud-based
system until the public health department could build capacity in its
immunization information system.

In contrast, officials in Maryland told us they did not encounter capacity
challenges, because they relied on the state health information exchange
organization—which had sufficient capacity—to lead their COVID-19 data
collection effort. According to officials at the state’s health information
exchange, the immunization information system received tens of
thousands of submissions each day, which would not have been feasible

33Patient matching generally relies on the use of demographic information such as a
patient’s name, date of birth, sex, Social Security number, or address, among other
information. Officials from California, Georgia, and Michigan told us they used a process
known as probabilistic matching when merging data from immunization information
systems and Medicaid. Probabilistic matching is an analysis to determine the overall
likelihood that two records are matches.
34The challenges of patient matching are not unique to the COVID-19 public health
emergency. See GAO-23-105540; and GAO, Health Information Technology: Approaches
and Challenges to Electronically Matching Patients’ Records across Providers,
GAO-19-197 (Washington, D.C.: Jan. 15, 2019).




Page 17                                GAO-24-106526 Medicaid COVID-19 Vaccination Data
for the immunization information system to handle. As a result, state
public health and Medicaid officials said they created processes to direct
immunization submissions through the state’s health information
exchange organization instead, which was accustomed to processing
large volumes of data prior to the public health emergency.

Inconsistent data capture. The large influx of new users submitting
vaccination data to immunization information systems also created
inconsistencies and challenges with the quality of vaccination data,
according to three selected states (Connecticut, Georgia, and Michigan),
and other reports. 35 For instance, providers approved to administer the
vaccination, such as paramedics and medical and nursing students, may
not have had prior experience submitting vaccination data to the
immunization information system, because they were not previously
required to do so. For example, among our selected states,

•   Michigan public health officials said that members of the National
    Guard helped enter data into the immunization information system,
    but their lack of familiarity with the system led to errors.
•   Georgia public health officials told us that records for some individuals
    vaccinated at a mass vaccination site had the same date of birth,
    which they believed to be incorrect as the date was also the default
    date for the field. This made it challenging to match these data to the
    state’s vaccination records.
Additionally, as we reported in March 2021, several factors contributed to
missing information on race and ethnicity in immunization information
systems’ COVID-19 vaccination records early in the COVID-19 vaccine
rollout. 36 Contributing factors included the lack of consistent collection and
reporting of this information by providers, and patient refusal to provide

35For example, according to the HHS Office of the Inspector General, state immunization
programs experienced challenges obtaining timely and complete vaccine administration
data from providers, which they attributed to having limited resources to sufficiently train
providers on how to use their data systems, including how to input data in the data
systems (e.g., immunization information systems) in a timely and accurate way. Further,
state immunization program officials reported that the immunization information system
onboarding process was particularly challenging and burdensome when some providers
had minimal to no prior vaccine experience. See Department of Health and Human
Services, Office of the Inspector General, Early Challenges Highlight Areas for
Improvement in COVID-19 Vaccination Programs, OEI-04-21-00190 (Washington, D.C.:
Jan. 31, 2023).
36Specifically, data collected from states and jurisdictions on race and ethnicity for COVID-
19 vaccine recipients as of March 8, 2021, were missing for almost half (46.7 percent) of
recipients who received at least one dose. See GAO-21-387.




Page 18                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
                               the information, according to CDC officials and stakeholders. 37 These
                               challenges affected the quality of race and ethnicity data available in
                               immunization information systems, but did not affect Medicaid programs’
                               data in our selected states, according to our review. Medicaid officials we
                               interviewed said they generally relied on their own demographic data.
                               Specifically, Medicaid officials in California, Georgia, Maryland, and
                               Michigan told us that when demographic data (e.g., race or ethnicity)
                               differs between Medicaid and the immunization information system, they
                               use Medicaid data (e.g., from Medicaid enrollment data). Medicaid
                               officials in some selected states said they have found their demographic
                               data to be more reliable than that captured by the immunization
                               information system. 38

Selected States and            State and federal officials we interviewed underscored that, following the
Federal Officials Identified   COVID-19 public health emergency, state policies remain important
                               drivers of vaccination data availability. That is, in part, because the
State Policies as
                               federal requirement for reporting COVID-19 vaccinations to immunization
Continuing to Influence        information systems—which increased the availability of vaccination data
Vaccination Data Available     that could be shared by public health departments with other entities,
to Medicaid Programs           such as Medicaid programs—is no longer in effect. 39
After the Public Health
                               More specifically, officials from four of the six selected states (California,
Emergency                      Connecticut, Georgia, and Maryland) told us their state policies continue

                               37CDC reported steps it took to work with states to improve demographic data
                               completeness, including sending weekly data quality reports to jurisdictions beginning in
                               February 2021. In April 2022, CDC reported that the percentage of COVID-19
                               vaccinations with known ethnicity had increased from 79 percent to 87 percent between
                               February and December of 2021.
                               38We and others have reported gaps in race and ethnicity data collected by state Medicaid
                               programs. For example, in April 2023, we reported that five of our six selected states had
                               unreliable data on the race and ethnicity of beneficiaries with intellectual and
                               developmental disabilities, limiting our ability to analyze the distribution of beneficiaries.
                               See GAO, Medicaid: Characteristics of and Expenditures for Adults with Intellectual or
                               Developmental Disabilities, GAO-23-105457 (Washington, D.C.: Apr. 24, 2023). See also
                               Medicaid and CHIP Payment and Access Commission, March 2023 Report to Congress
                               on Medicaid and CHIP (Washington D.C., March 2023). CMS is taking some steps to
                               improve Medicaid data quality. For example, CMS assesses the quality of race and
                               ethnicity data states collect through eligibility determinations and report to CMS’s
                               Transformed Medicaid Statistical Information System. The Transformed Medicaid
                               Statistical Information System captures a variety of data from state Medicaid programs to
                               support federal and state program management, financial management, and program
                               integrity activities.
                               39As previously noted, the federal requirement mandating providers administering COVID-
                               19 vaccinations to report COVID-19 vaccination data to immunization systems ended on
                               October 6, 2023, with the commercialization of the COVID-19 vaccine.




                               Page 19                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
to require providers to report all COVID-19 vaccination records to
immunization information systems following the conclusion of the COVID-
19 public health emergency. In contrast, officials from the remaining two
selected states (Idaho and Michigan) told us they have policies that only
require reporting by certain providers for children’s vaccines (which apply
to COVID-19 vaccinations for children, as well as to other types of
vaccinations for children). 40 Therefore, in these states providers are not
required to report on most COVID-19 vaccinations for adults. Officials
from both states said they continue to encourage providers to report
COVID-19 vaccinations for adults to the immunization information system
even though such reporting is no longer required. 41

Of the four selected states that require providers to submit vaccination
records for all age groups, officials from three states told us they
expanded their immunization reporting requirements—which apply to all
types of vaccinations—as a result of their experiences responding to the
COVID-19 public health emergency.

•   Maryland expanded its immunization reporting requirements in April
    2022 to include providers who were previously exempt from reporting
    to the state’s immunization information system, such as those working
    in nursing homes or long-term care facilities. 42 According to Medicaid
    and public health officials, the state immunization information system
    now requires reporting from all providers and health care settings for
    all vaccinations.
•   Connecticut enacted a state law in May 2022 requiring providers to
    report all vaccinations, regardless of age, to the state immunization




40According to Idaho officials, providers participating in the Vaccine for Children program
are required to report vaccination administration data to the immunization information
system for all children through 18-years of age. In contrast, in Michigan, all providers are
required to report vaccinations administered to children 20-years of age or younger,
according to state documentation.
41Although some states do not have policies requiring providers to report routine
vaccination data for adults to the immunization information system, providers may choose
to do so. For example, CMS and the Office of the National Coordinator for Health
Information Technology have encouraged providers to report this information to
immunization information systems through the development of certification standards for
electronic health records, which was incentivized through the implementation of the Health
Information Technology for Economic and Clinical Health Act.
42See MD. CODE HEALTH - GEN §18–109(d)(6)(I)3 (2022).




Page 20                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
    information system. 43 State officials told us that previously, providers
    were only required to report vaccination data for children 7 years of
    age and under. Additionally, as previously noted, this law permits the
    public health department to share patient-level immunization and
    other data with the Medicaid program, according to public health
    officials.
•   California enacted a state law requiring all providers beginning in
    January 2023 to report all vaccinations for all age groups to the state
    immunization information system. 44 According to public health
    officials, this law also requires providers to report race and ethnicity
    data and will help improve the quality of demographic information in
    vaccination records.
Because these changes involve increased reporting requirements, they
should increase the amount of vaccination data captured going forward,
compared to what was reported before the public health emergency, as
well as what may be shared with Medicaid programs. However, public
health officials in California and Maryland also noted their requirements
do not include any specific enforcement mechanisms, which may make it
challenging to obtain immunization data from some providers. California
public health officials noted that the COVID-19 public health emergency
made them more aware of the various types of providers in the state that
administer vaccines, which will help the state ensure these providers
continue to report to the immunization information system, as required.




43See Connecticut House Bill 5506 § 493, Pub. Act No. 22-118 (2022); CONN. GEN. STAT.
ANN. § 19a-25 (2022).
44See California Assembly Bill 1797, (2021) codified at CAL. HEALTH SAFETY CODE §
120440 (2022).




Page 21                               GAO-24-106526 Medicaid COVID-19 Vaccination Data
Selected States Used
COVID-19
Vaccination and Other
Data to Inform
Vaccination
Incentives and
Outreach Efforts, but
Effectiveness of
Individual Strategies
is Unclear
Selected States’ Medicaid   Medicaid officials in our four selected states with access to patient-level
Programs Used Patient-      COVID-19 vaccination data from immunization information systems
                            (California, Georgia, Maryland, and Michigan) described ways they used
Level COVID-19
                            those data during the public health emergency. For example, state
Vaccination Data for        Medicaid officials in three of the four states described using patient-level
Vaccine Incentive Efforts   vaccination data to implement two types of strategies: incentives and
and Targeted Outreach       targeted outreach. 45 The strategies targeted different groups, such as
                            managed care organizations, providers, or Medicaid beneficiaries.

Vaccination Incentives      State Medicaid officials in California, Maryland, and Michigan told us that
                            patient-level vaccination data helped them set COVID-19 vaccination
                            targets and financially reward managed care organizations that improved
                            vaccination rates. These states implemented incentive programs, with
                            various approaches, for managed care organizations to improve
                            vaccination rates, in cases when there was a lower than anticipated
                            vaccination rate. (See table 1.) For example, California developed its
                            incentive program because of disparities it identified in the vaccination
                            rate between Medicaid beneficiaries and the non-Medicaid population in
                            California. Specifically, California Medicaid reported that as of August 8,
                            2021, 48.7 percent of Medicaid beneficiaries aged 12 years and older had
                            received one COVID-19 vaccination dose, compared to 73.7 percent of all


                            45State Medicaid program and managed care organization officials described other
                            strategies they implemented that did not involve the use of patient-level COVID-19
                            vaccination data from immunization information systems. See appendix II for a description
                            of those strategies used.




                            Page 22                               GAO-24-106526 Medicaid COVID-19 Vaccination Data
                                                                 Californians of the same age group. 46 In response, the state’s incentive
                                                                 program established vaccination targets to increase the overall
                                                                 vaccination rate among Medicaid beneficiaries, as well as vaccination
                                                                 rates within certain Medicaid subpopulations.

Table 1: Selected State Medicaid COVID-19 Vaccination Incentive Programs for Managed Care Organizations

                                                                                                            Performance
 State              Description                                                                             period               Awards
 California         Program designed to increase first dosage of COVID-19     9/1/2021–                                          $187.5 million to all 25 organizations,
                    vaccine among unvaccinated beneficiaries aged 12 years    2/28/2022                                          ranging between $24,800 and $45.1
                    and older.                                                (6 months)                                         million per organization.
                    Managed care organizations could earn full or partial
                    payments based on performance across 10 performance
                    measures, and for developing a vaccination response plan.
                    Measures focused on individuals by age group, as well as
                    certain vulnerable populations.a
 Maryland           Program designed to increase full COVID-19 vaccination     1/2022–3/2022 (3                                  $4 million to all nine organizations,
                    (one or two doses, depending upon the vaccine              months)                                           ranging between $105,600 and
                    manufacturer) among unvaccinated beneficiaries aged 12                                                       $945,000 per organization.
                    years and older.
                    Managed care organizations received a fixed amount, $100
                    for each member vaccinated, within a set number of
                    members that varied by the organization’s enrollment size.
 Michigan           Program designed to increase first dosage of COVID-19                                   10/2020 – 9/2021     Fiscal year 2021: $0 awarded (no
                    vaccine among unvaccinated beneficiaries aged 16 years                                  (fiscal year 2021)   managed care organization met Tier 1
                    and older (fiscal year 2021) or 12 years and older (fiscal                              and                  or Tier 2 benchmarks).c
                    year 2022).                                                                             10/2021–9/2022       Fiscal year 2022: $53.9 million
                    Managed care organizations could earn payment for                                       (fiscal year 2022)   awarded to one of nine organizations.
                    reaching established vaccination benchmarks aligned with
                    the state public health department’s April 2021 vaccination
                    response plan:
                    •    Tier 1: 55 percent of beneficiaries resulted in 30
                         percent of award.b
                    •    Tier 2: 70 percent of beneficiaries resulted in 70
                         percent of award.
Source: GAO analysis of state documentation and interviews with state Medicaid officials. | GAO-24-106526

                                                                 Note: State officials reported using different strategies to fund the incentive programs. California
                                                                 Medicaid officials said they claimed a 50 percent federal match rate, and an additional 6.2 percent for
                                                                 certain medical services that was available due to enhanced federal matching authorized under
                                                                 federal law. Maryland Medicaid officials said they claimed the federal match rate of 50 percent for
                                                                 administrative services. Michigan Medicaid officials said they claimed the federal match rate of 100
                                                                 percent for COVID-19 vaccination administration that was available during the COVID-19 public
                                                                 health emergency. Medicaid officials in each state noted that the total awards fell within the



                                                                 46See State of California, Department of Health Care Services, “Medi-Cal COVID-19
                                                                 Vaccination Incentive Program,” All Plan Letter 21-010 (Revised) (Sacramento, Calif.:
                                                                 Mar. 7, 2022).




                                                                 Page 23                                             GAO-24-106526 Medicaid COVID-19 Vaccination Data
permissible payment limit for Medicaid managed care for incentive payments (i.e., up to 5 percent
above the capitation payment).
a
 For example, managed care organizations had to report on two of the following three measures:
percent of homebound beneficiaries who received at least one dose of a COVID-19 vaccine; percent
of beneficiaries 50-64 years old with one or more chronic conditions; and percent of primary care
providers who provided COVID-19 vaccines in their office. Additionally, two measures focused on
increasing vaccinations among the race and ethnicity groups with the lowest and second-lowest
baseline vaccination rates.
b
 The award was based on an inventive pool funded by monies the state recouped from managed care
organizations that did not spend projected COVID-19 vaccination administration funding. Managed
care plans were also required to submit a vaccination response plan to be eligible for an award.
c
  In fiscal year 2021, Michigan Medicaid officials said $40.4 million was recouped from managed care
organizations and returned to the federal government.


According to California Medicaid officials, their program resulted in
improvements to vaccination rates among Medicaid beneficiaries.
However, California Medicaid officials also said that disparities in
vaccination rates between Medicaid beneficiaries and the general
population remained. State officials indicated that these continuing
disparities may, in part, be related to the short time frame that the
incentive program was in effect (6 months), vaccination hesitancy, and
longstanding barriers, such as lack of transportation and difficulty taking
time off work, that Medicaid beneficiaries face in accessing vaccinations.
Officials in Maryland and Michigan indicated their programs had less of
an effect on COVID-19 vaccination rates than they had hoped, noting
similar reasons as California officials.

Selected managed care organizations in these three states also
developed incentive programs directed toward providers, beneficiaries, or
both. For example, according to Michigan Medicaid officials, all managed
care organizations offered provider incentives. Documentation for the
managed care organization in Michigan we interviewed indicated they
paid providers $10 to $100 per eligible beneficiary vaccinated, depending
on the overall vaccination rate for the provider’s eligible patients. 47

Additionally, most managed care organizations in all three states
(California, Maryland, and Michigan) offered beneficiaries incentives,
according to state officials. For example, California reimbursed 22 of its
25 managed care organizations because they opted to provide incentives

47Under this program, the managed care organization paid providers an incentive for each
eligible member that received at least one dose of the COVID-19 vaccine. For example,
providers with less than 55 percent of members vaccinated received $10 per member
vaccinated, and providers with at least 70 percent of members vaccinated received $100
per member vaccinated. To receive the incentive, providers were required to submit
vaccination data to the immunization information system within 3-days of administration.




Page 24                                     GAO-24-106526 Medicaid COVID-19 Vaccination Data
                    to beneficiaries, such as $50 gift cards. 48 Offering beneficiary incentives
                    was an effective strategy, according to managed care organization
                    officials in Michigan. In contrast, officials with a managed care
                    organization in Maryland told us they did not find this strategy effective
                    because of vaccine hesitancy among members. Findings in research
                    studies we identified also suggested that incentives can be helpful, but
                    are not particularly effective among the vaccine hesitant. 49

Targeted Outreach   Medicaid programs in California, Maryland, and Michigan also used
                    patient-level vaccination data to support efforts to target outreach to
                    Medicaid beneficiaries who had not yet received a vaccination or were
                    due for an additional vaccination. For example, Medicaid officials in two
                    states (California and Maryland) told us they provided patient-level data to
                    managed care organizations regarding their plan members to enable
                    those organizations to target outreach to and engage in one-on-one
                    conversations with beneficiaries to encourage vaccination. For instance,
                    officials from the California Medicaid managed care organization we
                    interviewed said they used that information to identify providers with the
                    highest percentage of unvaccinated beneficiaries. The officials said they
                    then sent these providers toolkits to help combat misinformation that
                    included posters, post cards for beneficiaries, and a script to use when
                    talking with patients.

                    Additionally, officials from the managed care organizations in all three
                    states said that patient-level data helped them determine which
                    beneficiaries to contact through text message campaigns or other
                    targeted communication, like email or mailings, to remind them to get
                    vaccinated or share information about the benefits of vaccination. For
                    instance, officials from the Michigan managed care organization said they
                    sent unvaccinated beneficiaries text messages containing information on
                    nearby clinics or CDC information about the vaccination, depending on
                    the beneficiaries’ responses to prompts in the text. These officials also
                    reported that their use of texting was more successful than phone call

                    48While the California Medicaid program did not provide direct incentives to beneficiaries,
                    managed care organizations could opt to provide non-monetary incentives (e.g., gift
                    cards) that did not exceed $50 in value per member. According to data provided by
                    California Medicaid officials, the state reimbursed these organizations for a total of $36
                    million, ranging from $2,400 to $12 million per organization.
                    49See Neil K.R. Sehgal, “Impact of Vax-a-Million Lottery on COVID-19 Vaccination Rates
                    in Ohio,” The American Journal of Medicine, vol. 134, no. 11 (2021); and Mireille
                    Jacobson et al., “Can Financial Incentives and Other Nudges Increase COVID-19
                    Vaccinations Among the Vaccine Hesitant? A Randomized Trial,” Vaccine, vol. 40, no. 43
                    (2022).




                    Page 25                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
                            outreach, and they plan to incorporate texting campaigns into future
                            efforts. One study we reviewed also identified text messaging and digital
                            communication as an effective strategy for reaching unvaccinated
                            individuals during the COVID-19 public health emergency. 50

                            In addition to incentives and targeted outreach, Medicaid officials in the
                            four selected states with access to patient-level COVID-19 vaccination
                            data from immunization information systems (California, Georgia,
                            Maryland, and Michigan) reported using that data to develop tools to track
                            vaccination rates. For example, Michigan officials told us they developed
                            an internal dashboard that tracked COVID-19 vaccination status for
                            beneficiaries in managed care plans across different demographics, such
                            as race and ethnicity, age, and geographic area. The dashboard provided
                            aggregate data on vaccination rates to help managed care organizations
                            monitor and improve vaccination rates.

Selected States’ Medicaid   Medicaid officials in five of our six selected states (California,
Programs Used Medicaid      Connecticut, Idaho, Maryland, and Michigan) also described using data
                            other than, or in addition to, immunization information system data to
Claims and Other Data to
                            increase vaccination rates among high-risk and vulnerable Medicaid
Increase Vaccination        beneficiaries, who are most at risk of adverse outcomes from COVID-19
Rates Among High-Risk       complications. According to CMS officials, the agency encouraged state
and Vulnerable              Medicaid programs to use all available data to help inform approaches for
                            vaccinating beneficiaries, and states used a variety of approaches. 51
Populations
                            Medicaid officials in five of the six selected states (California, Connecticut,
                            Idaho, Maryland, and Michigan) told us Medicaid claims data helped them
                            to identify high-risk beneficiaries, including those with existing medical
                            conditions or comorbidities, who were more likely to face hospitalization
                            from COVID-19. For instance, Connecticut Medicaid and managed care
                            organization officials told us they used this approach to focus efforts on
                            improving vaccination rates among high-risk groups. Michigan Medicaid
                            officials said claims data helped them identify and target efforts for
                            homebound individuals.


                            50See Lynett Ford et al., “Personalized Digital Health Communications to Increase
                            COVID-19 Vaccination in Underserved Populations: A Double Diamond Approach to
                            Behavioral Design,” Frontiers in Digital Health, vol. 4 (2022).
                            51For example, CMS’s COVID-19 Toolkit provided guidance and high-level
                            recommendations to state Medicaid programs, and recommended state Medicaid
                            programs collaborate with public health departments to increase COVID-19 immunization
                            rates and obtain immunization data.




                            Page 26                               GAO-24-106526 Medicaid COVID-19 Vaccination Data
                            In three of the six selected states (California, Connecticut, and Michigan),
                            Medicaid or managed care organization officials described using health
                            indexes, such as CDC’s Social Vulnerability Index or other state-specific
                            health indexes, to identify vulnerable populations and determine where to
                            target vaccination efforts. 52 For example, in Connecticut, officials from a
                            managed care organization told us that social vulnerability index data
                            helped them target communication about the vaccine to specific zip codes
                            with high vulnerability.

Effectiveness of Specific   While selected states implemented several strategies to increase
COVID-19 Vaccination        vaccination rates among Medicaid beneficiaries, state Medicaid officials
                            said that the nature of the COVID-19 public health emergency caused
Strategies Used by
                            challenges assessing the effectiveness of any specific strategies they
Selected States is          implemented. As a result, the effectiveness of any specific strategy
Unclear; COVID-19           remains unclear. For example, officials stated
Vaccination Efforts
                            •   it was necessary to implement multiple efforts concurrently to increase
Affirmed Importance of
                                vaccinations, so it is difficult to attribute changes in vaccination rates
Collaboration                   to any one effort;
                            •   many efforts (e.g., mobile clinics) were focused on increasing
                                vaccinations in communities at-large, not just among Medicaid
                                beneficiaries; and
                            •   some states did not have complete data on Medicaid beneficiaries
                                who received the COVID-19 vaccine. 53
                            Due to these challenges, several state Medicaid officials and CMS
                            officials told us they do not plan to assess the relative effectiveness of

                            52CDC’s social vulnerability index collects data on 16 social factors, including high
                            poverty, low percentage of vehicle access, or crowded households, to rank the social
                            vulnerability of geographic areas and to identify communities that might need additional
                            support during emergencies, including the COVID-19 pandemic. California used the
                            Healthy Places Index, developed by the Public Health Alliance of Southern California, to
                            identify vulnerable communities.
                            53Because the federal government purchased and distributed COVID-19 vaccines free of
                            charge during the COVID-19 public health emergency, Medicaid claims do not capture the
                            scope of all COVID-19 vaccines administered to Medicaid beneficiaries. According to
                            CMS officials, although the agency requires Medicaid programs to collect and report
                            claims data for instances in which Medicaid provided reimbursement for vaccination
                            administration, it does not require Medicaid programs to report such data when
                            vaccinations are administered or paid for by other entities. As such, according to CMS
                            officials, it is not possible for CMS to estimate vaccination rates during the COVID-19
                            public health emergency for Medicaid beneficiaries. CMS officials told us that now that
                            COVID-19 vaccines are paid for by Medicaid, there should be more consistency in the
                            capture of vaccination data in claims across states, which will in turn be reported to CMS.




                            Page 27                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
state strategies on COVID-19 vaccination rates for Medicaid
beneficiaries. 54

Among the four selected states that had access to patient-level COVID-
19 vaccination data from immunization information systems (California,
Georgia, Maryland, and Michigan), available data show disparities
persisted between vaccination rates for Medicaid beneficiaries and the
statewide population during the COVID-19 public health emergency.
Specifically, our review of state-reported data among these four states—
which vary by time period and age group—generally show between a 16
and 35 percentage point difference between the vaccination rate for the
Medicaid population and the rate for the statewide population.

State officials noted that various factors may have contributed to such
disparities. For example, Michigan officials noted that Medicaid
beneficiaries often are, in general, vaccinated at lower rates for other
types of vaccinations compared to the general population. According to
Medicaid officials in Michigan, this may be due, in part, to barriers noted
earlier, such as transportation challenges and vaccine hesitancy.
According to analysis conducted by the Medicaid and CHIP Payment and
Access Commission, in general, vaccination rates for influenza, tetanus,
and most other vaccines were lower for adult Medicaid beneficiaries than
for adults with private health insurance. 55

Although the effectiveness of specific strategies on improving COVID-19
vaccination rates among Medicaid beneficiaries is unclear, state and
federal officials told us the COVID-19 public health emergency affirmed
the importance of strong, collaborative relationships between state
Medicaid and public health departments to better leverage available data,
as well as ensure access to vaccinations and reduce barriers. 56 According

54California Medicaid officials told us they are in the process of evaluating their incentive
program for managed care organizations, which will include a review of managed care
organizations’ successes and challenges in meeting the program’s goals. Officials said
they anticipate that this evaluation may help to inform ongoing and future vaccination
efforts.
55See Medicaid and CHIP Payment and Access Commission, “Report to Congress on
Medicaid and CHIP” (Washington, D.C.: March 2022), chapter 2.
56The Association of Immunization Managers emphasized the value of collaboration
between Medicaid and immunization programs—including to overcome barriers related to
COVID-19—in its November 2020 checklist identifying ways to improve data exchange
between public health and Medicaid. See Association of Immunization Managers,
“Collaborating with Medicaid to Improve Vaccination Rates: A Checklist for Immunization
Program Managers” (Rockville, Md.: Nov. 21, 2020).




Page 28                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
to CDC and CMS officials, strong, collaborative relationships between
programs are important for the ongoing exchange and use of vaccination
data. Similarly, such relationships would be crucial during any future
public health emergency involving an infectious disease.

Medicaid officials in three selected states (Georgia, Idaho, and Michigan)
told us increased collaboration during the public health emergency
fostered more discussions with public health officials, including
discussions about data sharing and data use going forward. For example,
Georgia Medicaid officials told us the COVID-19 public health emergency
demonstrated how both Medicaid and the public health agency could
benefit from accessing one another’s data and noted that both agencies
are interested in exchanging data for other uses, such as addressing
maternal mortality.

Additionally, CDC and CMS officials noted that the COVID-19 public
health emergency amplified the importance of collaboration between state
Medicaid programs and public health departments to ensure Medicaid
beneficiaries obtain recommended vaccinations, and officials from both
agencies told us they continue to emphasize the value of such
relationships in their interactions with state officials. 57 In support of such
relationships, CDC funds a cooperative agreement focused on creating
collaborations between public health departments and Medicaid to better
understand barriers to immunization for Medicaid-enrolled populations




57The Medicaid and CHIP Payment and Access Commission also noted that COVID-19
highlighted existing limitations related to immunization information systems and data
sharing, and identified interoperability, data quality, and timeliness as some of the barriers
contributing to lower vaccination rates among adults enrolled in Medicaid compared to the
general population. They made several recommendations to address barriers, including
that Congress provide additional federal funds to improve immunization information
systems and require CMS, CDC, and other relevant agencies within HHS to release
federal guidance and implement standards to improve immunization information system
data collection and interoperability with state Medicaid data systems as well as electronic
health records. See Medicaid and CHIP Payment and Access Commission, “Report to
Congress on Medicaid and CHIP” (Washington, D.C.: June 2022), chapter 3.




Page 29                                  GAO-24-106526 Medicaid COVID-19 Vaccination Data
                  and improve immunization rates. 58 In September 2023, CDC awarded
                  additional funds under the cooperative agreement, which will run through
                  September 2026. According to CDC, this effort will also facilitate a
                  broader learning network consisting of Medicaid and public health officials
                  to help share promising and best practices for improving vaccination
                  rates.

                  We provided a draft of this report to HHS for review and comment. HHS
Agency Comments   provided technical comments, which we incorporated as appropriate.

                  We are sending copies of this report to the Secretary of Health and
                  Human Services, the appropriate congressional committees, and other
                  interested parties. In addition, this report will be available at no charge on
                  the GAO website at http://www.gao.gov.

                  If you or your staff members have any questions about this report, please
                  contact me at (202) 512-7114 or lathamc@gao.gov. Contact points for
                  our Offices of Congressional Relations and Public Affairs may be found
                  on the last page of this report. Major contributors to this report are listed
                  in appendix III.




                  Catina B. Latham
                  Director, Health Care




                  58Under the first iteration of the CDC-funded cooperative agreement, which began in
                  2017, five states (Colorado, Hawaii, Kentucky, Montana, and New Mexico) participated.
                  The second iteration began in 2020 and included six states (Louisiana, Michigan, Texas,
                  Washington, Wisconsin, and Wyoming). Documentation describing outcomes from the
                  second iteration indicate regular collaboration between Medicaid and immunization
                  programs was a successful outcome in three states (Michigan, Texas, and Washington)
                  and resulted in joint guidance and updates to health plans and beneficiaries. Additionally,
                  four state public health departments (Louisiana, Michigan, Texas, and Washington) noted
                  they improved their ability to regularly share immunization data with the Medicaid
                  program, and a fifth state’s public health agency (Wyoming) began the process of setting
                  up such data sharing.




                  Page 30                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
Appendix I: Medicaid Program Changes to                       Appendix I: Medicaid Program Changes to
                                                              Support COVID-19 Vaccination Activities


Support COVID-19 Vaccination Activities

                                                              Congress and the Centers for Medicare & Medicaid Services (CMS)
                                                              made temporary changes to the Medicaid program during the public
                                                              health emergency to help ensure beneficiaries had access to COVID-19
                                                              vaccinations. 1 For example, to incentivize providers to administer the
                                                              COVID-19 vaccination to Medicaid beneficiaries, states were permitted to
                                                              increase the provider reimbursement for that service. (See table 2.)
                                                              These changes were permitted through a period of time after the end of
                                                              the public health emergency, depending on the specific flexibility.

Table 2: Examples of Medicaid Program Changes to Respond to the COVID-19 Public Health Emergency

Description                                                                                       Rationale
Federal law required states to provide and administer COVID-19                                    Eliminated cost as a barrier to vaccination.
vaccines to Medicaid beneficiaries free of cost.
Federal law provided enhanced federal matching rate to cover costs                                Reduced the costs to states in increasing vaccination rates
associated with COVID-19 vaccines and administration.                                             among Medicaid beneficiaries.
CMS allowed states to align fees paid to Medicaid providers to                                    Incentivized providers who do not generally administer
administer the vaccine with Medicare payments rates.a                                             vaccinations to Medicaid beneficiaries.
Federal law made it possible for states to permit additional categories Increased range of providers that can be reimbursed for
of providers (e.g., pharmacists, pharmacy technicians) to administer    administering vaccinations to Medicaid beneficiaries.
the COVID-19 vaccination in states where they did not already have
authority.b
CMS provided coverage and payment at an enhanced federal                                          Helped address vaccine hesitancy by helping beneficiaries and
matching rate for health care providers to provide patients or                                    their families learn about vaccines from trusted health care
caregivers counseling about the COVID-19 vaccination when this                                    providers.
counseling is covered for Medicaid beneficiaries under the age of 21.
CMS allowed states to provide vaccination coverage to Medicaid                                    Increased types of individuals eligible to obtain COVID-19
beneficiaries in limited coverage groups, such as individuals only                                vaccinations free of charge through Medicaid.
eligible for family planning benefits.c
Source: GAO analysis of Centers for Medicare & Medicaid Services (CMS) COVID-19 guidance. | GAO-24-106526
                                                              a
                                                               CMS established reimbursement rates under the Medicare program for costs associated with
                                                              administering the COVID-19 vaccination at $40 and permitted state Medicaid programs to apply for
                                                              approval to adopt the same reimbursement rates to offset higher administration costs, such as to
                                                              offset costs for providers in rural areas or transportation costs.
                                                              b
                                                               See, e.g., Pub. L. No. 109-148, Division C, 119 Stat. 2680, 2818 (2005) and declarations issued
                                                              thereunder.
                                                              c
                                                                Federal law typically limits states to providing limited benefits to these beneficiaries. See Centers for
                                                              Medicare & Medicaid Services, Center for Medicaid and CHIP Services, Medicaid, Children’s Health
                                                              Insurance Program (CHIP), and Basic Health Program (BHP) Related Provisions in the American
                                                              Rescue Plan Act of 2021, Informational Bulletin (Baltimore, Md.: June 2021).


                                                              1Medicaid allows significant flexibility for states to design and implement their programs.
                                                              For example, states can request waivers of certain federal requirements to target certain
                                                              populations or test new or innovative approaches for managing the health care needs of
                                                              beneficiaries. In addition to its normal authority to approve these state waiver applications,
                                                              CMS has additional authorities to waive Medicaid requirements to help ensure the
                                                              availability of care in certain emergency circumstances.




                                                              Page 31                                          GAO-24-106526 Medicaid COVID-19 Vaccination Data
Appendix II: Barriers to COVID-19
              Appendix II: Barriers to COVID-19 Vaccination
              and Strategies to Address Them


Vaccination and Strategies to Address Them

              According to the Centers for Disease Control and Prevention (CDC),
              barriers can hinder access to and receipt of vaccinations within certain
              communities. To increase COVID-19 vaccination rates, CDC encouraged
              state and local jurisdictions to use a variety of strategies to help improve
              COVID-19 vaccination rates. 1

              According to CDC, barriers to COVID-19 vaccination include the
              following:

              •   Some individuals may face challenges traveling to a provider
                  administering vaccinations due to lack of transportation or inability to
                  take time off work. Additionally, people with disabilities, homebound
                  individuals, or individuals who reside in long-term care facilities may
                  not be able to travel to get a vaccine. An individual may also lack
                  internet access or the technical skills required to search online for
                  vaccination sites or appointments.
              •   Some individuals lack the information they need to understand the
                  risks, benefits, and background of vaccine development to make an
                  informed decision about getting vaccinated.
              •   Some individuals may have mistrust of certain institutions including
                  government, medical institutions, and media, which can affect
                  decisions about vaccination. 2
              CDC guidance suggests that states consider implementing the following
              strategies to help address barriers:

              •   Support school- and work-based vaccination clinics to help reach
                  individuals with limited availability to seek out vaccination.
              •   Provide community- or neighborhood-based vaccination clinics to help
                  to reach individuals who are homebound or specific neighborhoods
                  with low vaccination rates.
              •   Partner with trusted community members (e.g., faith leaders) or
                  trusted messengers (e.g., experts or health care providers) to help
                  share important health information.




              1For example, see Centers for Disease Control and Prevention, COVID-19 Vaccination
              Field Guide: 12 Strategies for Your Community (August 2021).
              2See GAO, COVID-19: Federal Efforts to Provide Vaccines to Racial and Ethnic Groups,
              GAO-22-105079 (Washington, D.C.: Feb. 7, 2022).




              Page 32                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
                                          Appendix II: Barriers to COVID-19 Vaccination
                                          and Strategies to Address Them




                                          •   Offer vaccinations during routine patient visits or reminding individuals
                                              of upcoming vaccination appointments through phone calls or text
                                              messaging using appropriate language-based or translation services.
                                          Medicaid and managed care officials in our six selected states (California,
                                          Connecticut, Georgia, Idaho, Maryland, and Michigan) described various
                                          strategies they used to help improve COVID-19 vaccination rates. These
                                          strategies did not involve the use of patient-level COVID-19 vaccination
                                          data from immunization information systems. (See table 3.)

Table 3: Examples of Strategies to Improve COVID-19 Vaccination Rates Used by Medicaid Programs in Six Selected States

State              Strategy
California         Medicaid officials told us that they sent newsletters to beneficiaries’ households, which included information
                   about the COVID-19 vaccination.
                   Officials at one of the state’s managed care organizations described implementing a number of strategies. The
                   managed care organization
                   •    provided newsletters to members to combat misinformation about the vaccine;
                   •    partnered with over 40 community-based, education, public health, and faith-based organizations to sponsor
                        over 50 vaccination events in vaccine-hesitant neighborhoods experiencing low vaccination rates, primarily
                        targeting Black and Latino communities;
                   •    shared information about the vaccine at events and through social media;
                   •    partnered with other health plans, health departments, local sports teams, social media influencers, and
                        celebrities to encourage vaccination;
                   •    coordinated with a transportation vendor to schedule transportation for COVID-19 testing and vaccination,
                        and to waive the 2-day appointment scheduling requirement for transport; and
                   •    coupled vaccination clinics with other services such as food pantries or back-to-school giveaways.
Connecticut        Medicaid officials told us they
                   •    covered the cost of transportation to vaccination sites, transportation that would ordinarily not be
                        reimbursable;
                   •    partnered with the state public health department to sponsor vaccination clinics and develop community-
                        based strategies to conduct outreach to populations disproportionately impacted by COVID-19 (e.g.,
                        partnered with barber shops, hairdressers, and other places frequented by members of the Black and
                        Hispanic communities); and
                   •    partnered with the state public health department to notify communities where mobile vans were
                        administering COVID-19 vaccinations.
                   Officials at the state’s managed care organizations described implementing a number of strategies:
                   •    Assisted beneficiaries in scheduling COVID-19 vaccination appointments.
                   •    Conducted outreach to beneficiaries through phone calls and text.
                   •    Partnered with the state public health department, as well as social services in the state, to provide
                        information about the vaccine.
                   •    Conducted general outreach to providers and provided information about the COVID-19 vaccine through
                        newsletters.
                   •    Provided vaccination information more broadly through social media, webinars, and townhall events.




                                          Page 33                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
                                                                 Appendix II: Barriers to COVID-19 Vaccination
                                                                 and Strategies to Address Them




 State                         Strategy
 Georgia                       Officials at one of the state’s managed care organizations described that their organization
                               •    broadly shared information about the vaccine with beneficiaries; and
                               •    partnered with community organizations, local sports teams, and local influencers to encourage
                                    vaccinations.
 Idaho                         Medicaid officials told us they
                               •  sent postcards to households with vaccine-eligible members that provided information on the COVID-19
                                  vaccine, and
                               •  shared information about the vaccine with providers through newsletters and other communications.
 Maryland                      Medicaid officials told us they
                               •    collaborated with school-based health centers, federally qualified health centers, local health departments,
                                    as well as providers in target areas to improve vaccination rates;
                               •    partnered with the state’s call center to conduct outreach and encourage vaccination in certain geographic
                                    regions; and
                               •    developed partnerships with the NAACP and Casa de Maryland to address vaccine hesitancy.
                               Officials at one of the state’s managed care organizations described that they
                               •    conducted outreach to beneficiaries through phone calls and texts;
                               •    shared vaccination information with providers;
                               •    partnered with the state public health department, as well as other managed care organizations in the state,
                                    to provide information about the vaccine at events;
                               •    partnered with a local sports team to encourage vaccinations; and
                               •    partnered with a local organization to conduct community-based outreach to share information with
                                    beneficiaries, including QR codes that members could scan to get vaccination information.
 Michigan                      Medicaid officials told us they
                               •    partnered with the state public health department to sponsor vaccination clinics and develop community-
                                    based strategies; and
                               •    provided vaccination information to beneficiaries to combat misinformation about the vaccine.
                               Officials at one of the state’s managed care organizations described that their organization
                               •    used a texting campaign to share vaccination information with beneficiaries;
                               •    assisted with scheduling transportation to vaccination appointments;
                               •    partnered with pharmacies to set aside special vaccination appointment times to allow individuals more
                                    flexibility to schedule appointments;
                               •    used a consumer advisory committee to better understand and identify trusted individuals within the
                                    community; and
                               •    developed partnerships with trusted individuals, such as those in churches or community centers, to share
                                    information about the vaccine.
Source: GAO review of information collected from Medicaid programs and managed care officials in selected states. | GAO-24-106526




                                                                 Page 34                                                 GAO-24-106526 Medicaid COVID-19 Vaccination Data
Appendix III: GAO Contact and Staff
                  Appendix III: GAO Contact and Staff
                  Acknowledgments


Acknowledgments

                  Catina B. Latham, (202) 512-7114 or LathamC@gao.gov
GAO Contact

                  In addition to the contact named above, Shannon Legeer (Assistant
Staff             Director), Kimberly Lloyd Perrault (Analyst-in-Charge), Benjamin T.
Acknowledgments   Feldman, Joy Grossman, Emma Hultgren, Drew Long, Monica Perez-
                  Nelson, Andrea E. Richardson, and Ethiene Salgado-Rodriguez made
                  key contributions to this report.




                  Page 35                               GAO-24-106526 Medicaid COVID-19 Vaccination Data
Related GAO Products
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             Electronic Health Information Exchange: Use Has Increased, but Is Lower
             for Small and Rural Providers. GAO-23-105540. Washington, D.C.: April
             21, 2023.

             COVID-19: HHS Funds Allocated to Support Disproportionately Affected
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             Adult Routine Vaccinations: Adult Rates Vary by Vaccine Type and Other
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             COVID-19: Pandemic Lessons Highlight Need for Public Health
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             COVID-19: Current and Future Federal Preparedness Requires Fixes to
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             COVID-19: Federal Efforts to Provide Vaccines to Racial and Ethnic
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             COVID-19: Sustained Federal Action Is Crucial as Pandemic Enters Its
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             Medicaid Information Technology: Effective CMS Oversight and States’
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             Health Information Technology: Approaches and Challenges to
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             Electronic Health Records: Nonfederal Efforts to Help Achieve Health
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             Electronic Health Records: HHS Strategy to Address Information
             Exchange Challenges Lacks Specific Prioritized Actions and Milestones.
             GAO-14-242. Washington, D.C.: March 24, 2014.




             Page 36                        GAO-24-106526 Medicaid COVID-19 Vaccination Data
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