1. What’s New with VFC? A Lot
So What’s New with VFC? The short answer is a lot. Our plans for today’s workshop is to highlight the changes to two important areas of the VFC program Provider Recruitment and Enrollment and Fraud and Abuse. After a brief overview of the changes- the majority of the workshop will open for questions and answers to our panelists.
The first significant change is the logo- the train is leaving the VFC Station and is being replaced by trendier logo that reflects the addition of adolescent vaccines.

2. The changing face of VFC
So Here is the new VFC logo that will go up on the VFC website and grace the cover of the new VFC Ops Guide

3. Why must VFC change?
New vaccines + new populations = ↑VFC program costs
Changes require CDC and grantees to focus on the integrity of VFC program through implementation of requirements in VFC Operations Guide
Deliverables from grantees to CDC
To validate and document to OMB that the program is being implemented appropriately
Make CDC headquarters more aware of programmatic successes and challenges at the grantee level
Identify and share best practices among grantees
The addition of new (and costly) pediatric and adolescent vaccines raised the VFC budget to new heights. The increased budget and expanding focus to include adolescents required CDC to closely examine the guidance available to grantees from CDC to ensure that that the funds are being used as intended by the VFC legislation.
The focus of the new VFC Ops Guide will be providing more specific guidance on the required aspects of the VFC program. A part of this change CDC/ISD will initially requiring submission of several deliverables from the grantees by the end of There are three main purposes for these deliverables:
-Validate and document to OMB that the VFC Program is being implemented appropriately.
-Make CDC Headquarters more aware of successes and challenges at the grantee level
-Identify and share best practices among grantees
The two areas that will be the focus of today’s panel discussion are provider recruitment and enrollment and fraud & abuse.

4. How will changes be communicated?
This workshop
2008 Program Announcement
2007 VFC Operations Guide
2007 Immunization Program Operation Manual (IPOM)
VFC/AFIX Quarterly Conference Calls
Other forms of communication
The VFC Program changes will communicated over the course of the next several months in many different ways and this slide illustrates some of those methods

5. Provider Recruitment and Enrollment
The first area that we will review with some significant changes is Provider Recruitment & Enrollment

6. Provider Recruitment & Enrollment Changes (1)
VFC Provider Requirements
Nine (9) federal requirements
Decrease in the number of requirements from 11
Additional requirements
Grantees have flexibility to add some additional requirements related to storage & handling without approval from CDC
Acceptable additions are located on page five (5) of the module
Several of the provider requirements have combined resulting in a decrease from 11 requirements in the 2002 VFC OPS guide to 9 in the new version
The 2002 VFC Ops Guide include wording that no additional requirements could be added to the provider enrollment form without approval of the CDC – since the focus of the VFC program for the near future will focus on the integrity of the program it was decided to allow grantees to incorporate some additional requirements r/t S&H without needing approval from CDC. The grantee has the ability to pick and choose from a list located on page 5 in the draft module

7. Provider Recruitment & Enrollment Changes (2)
Formal method for grantees to request additional provider requirements specific to their locale
Must submit request even if requirement is on 2007 provider enrollment form
The 2002 VFC Ops guide stated:
States must not impose additional requirements for enrollment with out prior approval from the CDC.
The problem with this statement was it did not include a process to formally document change requests to the provider enrollment form or document approval. To standardize the change request process a formal method will be in place for grantees to request additional provider enrollment requirements. This will become effective for All additional requirements will have to go through this process even if these requirements are currently on the 2007 provider enrollment form.

8. Provider Recruitment & Enrollment Changes (3)
Formal method for tracking replacement of “borrowed” VFC vaccine
Standardized reporting form for providers to document the reason for borrowing from VFC vaccine and the date the VFC doses were replaced with private stock and submit to grantee for review
Grantees should incorporate review of replacement dose reports into routine activities
Another item from the OPS guide is “borrowing” of vaccine. “While it is permissible to occasionally borrow from one vaccine inventory to serve individual children, this vaccine must be replaced from the other source and this practice must be the exception rather than the rule.” However, there was no guidance on how this should be monitored or used for accountability purposes at the grantee level specifically when VFC vaccine was borrowed.
Again- since the focus is program integrity.
In the 2007 Ops Guide, there is a report that must be completed by the provider and submitted to the Immunization program if borrowing of VFC vaccine occurs. In turn, the grantee should incorporate review of these reports into their fraud and abuse and accountability activities.

9. Provider Recruitment & Enrollment Changes (4)
“Key Educational Concepts” are identified for each requirement
Elimination of the Provider Enrollment Form Template in the Appendices
A new component in the provider recruitment and enrollment and module for 2007 are “Key Educational Concepts” for each of the 9 requirements. This section under each of the requirements list what the provider and office staff must understand about each requirement.
In late fall of 2006 Program Operations Branch conducted a review of grantees provider enrollment forms- 51 were reviewed and all had created their own form so it appeared to be unnecessary.

10. What did not change?
Still identify one primary provider to sign enrollment form and list on enrollment form all providers in office that can order vaccines to be administered
Provider Profile and Enrollment form updated annually
A few key items related to provider enrollment and recruitment have not changed:
One Primary provider signs the enrollment form and other providers in the office are listed on the form.
Enrollment forms and Provider Profiles are to be updated annually.

11. Fraud and Abuse
The other module that will be discussed today is Fraud and Abuse there are some significant changes and will require grantees to submit to submit their fraud and abuse policy to CDC no later than December 31st The contents of the policy based on the requirements in this module.
This module was developed with input from CDC’s legal counsel amd CMS’s legal counsel and their Medicaid Integrity group.

12. Fraud and Abuse Requirements (1)
Written fraud and abuse policy
Submission to CDC by December 31, 2007
Seven components
Designate a Fraud and Abuse Coordinator and back-ups
“Identification of enforcement agencies that will receive referral of potential fraud and abuse cases and the process for referral”
The biggest change is the written fraud and abuse policy and submission to CDC by December 31st, The fraud and abuse policy has 7 requirements. Several requirements have multiple activities. The next few slides highlight some of the more significant requirements/components/activities:
The first item each grantee should do is to designate a fraud & abuse coordinator and at least two back ups. It should be associated with a position such as the program manager or VFC coordinator. This person makes the decision where a potential case is referred, makes the referral and notifies the appropriate governmental agencies.
A key component is identification of enforcement agencies that will receive referrals of potential cases and the process for that referral

13. Fraud and Abuse Requirements (2)
Describe the process for implementing activities to detect and monitor for fraud and abuse into daily operations of the VFC program:
Staff education on potential F &A situations and how to address potential situations
Provider Education
Timeframe of 5 working days between identification of situation and referral to external agency or educational intervention
This requirement is the heart of how fraud and abuse is monitored for and prevented at the program level
This slide identifies several of the key activities related to this requirement/component are listed on this slide:
-Staff Education on how to identify possible F&A and how to deal with different situations
-Provider Education for lack of knowledge related to the VFC program
-Maximum timeframe of 5 working days between identification and referral to external agency

14. Fraud and Abuse Requirements (3)
Incorporate accountability measures into daily VFC activities to assist in the monitoring and detection of fraud & abuse
Mandatory reporting requirements to CDC and CMS
Additional Fraud and Abuse Activities
City and state grantees must collaborate in policy development
Two other components of the fraud abuse policy are incorporating accountability into monitoring for Fraud and abuse
And reporting fraud and abuse to both CMS and CDC
Finally in situations where there is both state and urban exist – all grantees must work together to develop certain components of the fraud and abuse policy to standardized reasons/situations to referral the same agency. We are trying to Avoid significantly different referral situations by grantees to the external agencies.

15. Summary
The additions of new vaccines and new populations to the VFC program require a renewed focus on improving the integrity of the VFC program at all levels