I am an internist in private practice. I believe this is an ill conceived effort to provide people more opportunities to receive flu shots. The record keeping/documentation requirements are more difficult than you estimate and this results in further fragmentation of care.
Flu shots are widely available and advertised as "free" for Medicare and Medicaid patients. A more appropriate terminology would be "paid for by tax revenues". The obstacle is the wide spread belief that these shots will give people the flu. The only other obstacle we encounter is that some years the supply of the vaccine is limited and when available it is sometimes purchased by large chains requiring that patients to there for the vaccine.
Federal and private dollars would be better spent on education that a bunch of record keeping. Having every patient who enters a facility from September to February every year have to sign off that they had or refuse the vaccine is a lot of work and each of these regulations interrupts care and makes it less efficient.
Remember, you cannot go to WalMart, most groceries, all pharmacies and many other widely accessible locations without seeing a sign for "free flu shots." Availability is not the obstacle.
NC
This is comment on Proposed Rule
Medicare and Medicaid Programs: Influenza Vaccination Standard for Certain Medicare and Medicaid Participating Providers and Suppliers
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