COVID-19 vaccine shots setting, bending bar on data standards
This wasn’t supposed to happen.
At least it wasn’t designed to happen this way. Or maybe more design was needed.
But it did happen.
Back in late April at a southwest suburban Chicago mass vaccination center (MVC), healthcare workers administered the wrong branded vaccine to eight persons receiving their second shots. They received one brand for their first shot and the other brand for their second shot.
As healthcare experts tiptoed around the possibility of some type of adverse reactions, none was recorded – or at least reported to the media.
However, the incidents amplify a salient question: If the vaccine dosage bottles sported the proper bar codes or passive radio frequency identification (RFID) tags on the packaging, and the healthcare workers properly scanned the labels to match with a patient’s vaccination record kept by administrators in the county or state health department, how would this have happened? Further, how might the adoption and implementation of product data standards have affected the process and situation to follow?
Reporter Rebecca Robbins highlights another issue as she wrote in The New York Times in late April that “millions of Americans are not getting the second doses of their COVID-19 vaccines, and their ranks are growing.” She cites data received from the Centers for Disease Control and Prevention (CDC) that “more than five million people, or nearly 8% of those who got a first shot of the Pfizer or Moderna vaccines, have missed their second doses.”
One of the only ways for the CDC to know that is if the federal agency tracks usage data provided by state and county health departments.
The same process used to track and trace the authenticity and production of drugs and devices for recalls and usage also can be used to track and trace patients as recipients, thereby closing the loop.
“Because of the reliance on experienced manufacturers and on established distribution partners, there are systems in place to label and track shipments as well as record what products and lots are included,” acknowledged Keith Lohkamp, Senior Director, Industry Strategy, Workday. “This facilitates the exchange of information electronically so shipments and individual lots can be tracked to their destination.”
POU needs 4-1-1
Questions linger as to what happens once the individual lots are used at their destination or the point of use.
“Most pharmaceutical products, including vaccines, are labeled with bar codes containing standardized data that includes GS1 Global Trade Item Numbers (GTINs) with the U.S. FDA National Drug Code (NDC) for unique product identification, as well as expiration dates, serial numbers and lot numbers,” said Angela Fernandez, Vice President Community Engagement, GS1 US. “Using global data standards, such as GS1, allows all stakeholders to communicate effectively about products’ movement through the supply chain from manufacturer all the way to the patient.
“Standards enable robust track and trace processes, accurate inventory management and so much more – all critical factors for safe, effective and efficient distribution,” Fernandez continued. “Sharing standardized data between suppliers, wholesale distributors and dispensers makes it possible for all to understand what products are on order and where they are located – in shipping process or already onsite. This visibility helps ensure that clinicians can access them when needed. It also enables track and trace by assigning standardized product and location identifiers that can be captured and stored automatically at every point in the supply chain, maintaining those unique identifiers throughout a product’s journey for reliable information exchange and traceback capability. Fully implemented across the supply chain, standards keep products from ending up ‘lost’ in the chain, delaying or complicating inventory and availability for use.”
But while inherently valuable, it’s not enough just to adopt and implement data standards, according to Fernandez.
“The key to making the most of standards is full implementation of a well-managed data quality program that is incorporated in day-to-day operations,” she insisted. “Pharmaceutical manufacturers have been building their technology and data management infrastructure for several years now, leveraging GS1 Standards to meet regulatory requirements and improve supply chain visibility. As healthcare providers obtain scanners and train personnel on how to use them at point of care, all of the relevant product data can be captured, shared and accessed by stakeholders for full traceability.”
“Couple this with Health Information Exchange (HIE) under Meaningful Use – which facilitates electronic transport of patient data from medical records – and we could record and share if a patient has received a vaccine, garnering supply visibility down to the lot number,” Gomberg indicated. “With COVID-19, there is a critical need to accurately identify and match people to their vaccine administration data since there are multiple vaccinations available, some requiring multiple doses, and people may receive their first and second vaccine doses in different locations.”
Further, Gomberg opines that this process could be applied to personal protective equipment (PPE), expanding the use of Unique Device Identification (UDI) beyond recording implantable devices in patient medical records also to include PPE in clinical environments to better track usage and need.
To each his/her own
Yet, the key COVID-19 vaccine manufacturing and distribution services have concentrated their efforts on bulk container-based supply chain tracking and tracing and temperature monitoring, according to Chris Caulfield, Vice President, Temptime Operations, Zebra Technologies.
“The Biden Administration’s desire to accelerate vaccination throughput via a network of mass vaccination sites and retail pharmacies will require the addition of a strong vial-based focus to vaccine supply chain tracking and tracing and temperature monitoring,” Caulfield urged. “This is due to the workflows at local vaccination sites, including onsite vaccine vial management, patient injection recordation, second dose administration tracking, and wastage rate data collection. All of these workflows require vial-level information that lends itself to 2-D bar coding and scanning – as an alternative to manual data entry.
“Moreover, the data needed to identify counterfeit product or support product recalls will require vial-level detail,” he added.
Caulfield recommends that in the short term, 2-D bar code and scanning technology can help fulfill the track-and-trace goal, consistent with the policy noted in the Drug Supply Chain Security Act of 2013.
Vaccine manufacturer-affixed RFID tags on multi-pack boxes can help, too, as they can be scanned at any point in the supply chain, according to Caulfield. “This enables automated visibility of product shipments at the lot/batch level and accountability for vaccine dose management until the last mile delivery. RFID tags provide another layer of anticounterfeiting technology and allow an automated means of expediting vaccine dose receipt, distribution, and use,” he added. Further, using the GS1 standard to represent “item identification and other extended data fields will enable all supply chain operations to encode and read this data without the need for proprietary or custom arrangements.”
Carl Henshaw, Director, Standards Implementation, Vizient, homed in on the product temperature requirements as a valid and reliable reason for tracking, tracing and data standards use.
“The Moderna and the Pfizer vaccines are both based on mRNA technology that requires much colder temperatures to remain stable. For example, the Pfizer COVID-19 vaccine must be stored between -112 and -76 Fahrenheit,” Henshaw said. “To effectively administer these types of vaccines, the ability to demonstrate that the Cold Chain remains unbroken is critical. Standards from the Drug Supply Chain Security Act (DSCSA) require that to remove the threat of counterfeit and stolen products from the market, the chain of custody must begin with the manufacturer, continue on to the distributor and then the pharmacy. Those data standards include labeling the various levels of vaccine packaging and ensuring material handlers at vaccine sites have machine-readable codes for appropriate tracking.”
The U.S. Food and Drug Administration (FDA) requires items, like PPE, bear a unique device identifier (UDI) for that data to be submitted to the federal agency’s Global Unique Device Identification Database (GUDID). The UDI represents the combination of a device identifier (GTIN/UPN/ISBT128) and a production identifier (lot/batch/serial number/expiration date, manufactured date).
“While many manufacturers apply barcodes that meet these requirements already ahead of schedule, not everyone does because it is not yet mandated,” Henshaw said. The FDA began phasing in standards by device class in 2014. The final phase, involving Class I and unclassified devices, of which PPE is categorized, has been postponed twice with the requirement to comply pushed to September 2022.
“Once UDI standards are fully implemented, tracking PPE will be easier,” he assured.
Four-leafed closer
Carrie Gorman, Account Executive, Healthcare, Tecsys Inc., encapsulates the premise and promise of global data standards in four ways.
The first involves demand planning and forecasting, which emerged as a hot button at the start of the pandemic in early 2020.
“Global data standards – worldwide, not just at a federal level – can provide manufacturers with actionable data to enable accurate volumes of vaccine production and be much better prepared when the next pandemic or emergency comes along,” Gorman said. “This is the No. 1 lesson that COVID-19 has taught us with regard to PPE: There wasn’t a shortage of PPE as much as there was a shortage of data that manufacturers needed to produce the right quantity of PPE. Applied to a two-dose vaccination effort, consistent data standards ensure accurate data is shared with the state and the manufacturer to report actual regional demand for second doses.”
The second spans interoperability.
“Consistent data standards around the world would mean that all systems can digest, store, track and share the same data across systems,” she continued. “This is a challenge today in healthcare procurement. One distributor may abbreviate the [Unit-of-Measure] (UOM) Case as CA and another distributor uses CS. When data like UOM is inconsistent, the systems usually need to be manually updated to ensure accuracy. Aligning on a standard would eliminate the risk of ordering the wrong item or the wrong quantity of items.”
The third covers traceability.
“As basic as it sounds, consistently applied data standards allows for accurate reconciliation of the location of vaccines during transport and administration processes — enabling a true and complete chain of custody,” Gorman indicated. “Unfortunately, today, this level of data is not consistent across state lines or countries, which fragments the data being used to report on distribution and administration. That degree of visibility means if there is an error that occurs during the distribution process – truck is in an accident, vaccines are spoiled in route or late to the site – having accurate data standards can help easily identify which vaccines were impacted.”
The fourth ensures labor optimization.
“From an efficiency standpoint, juggling data standards is a major drain on labor,” she noted. “One large health system’s Cath Lab administrative director estimates the annual cost for participating in and supporting cardiac data registries is over $1 million and employs 15 highly skilled registered nurses.”
Gap analysis
As a snapshot of supply chain organization and momentum, COVID-19 vaccine production, distribution and administration has unearthed several questions and concerns that are inherently solvable, according to Ashok Muttin, Founder & CEO, SupplyCopia.
“Tracking vaccines from the point of manufacture through distribution to the point of care – wherever that may be – has illuminated more of the gaps we have in supply data standards,” Muttin noted. “While COVID-19 vaccine lot data is consistently identified and tracked, challenges occur in the last mile of distribution, and disparate systems make it difficult to bridge gaps. At the end of this process, do we know where all of the data will be and how to access it? How much is now on paper? What processes are in place to gather data from different locations? We have to close these gaps. Yet, it’s easy to see how challenges are exacerbated in the example we’re living through today, with vaccines requiring multiple doses, and potentially booster shots that also must be tracked.”
Better supply chain tracking mechanisms would help identify “wastage” and whether damaged vaccines are destroyed, helping to prevent black market resale of damaged doses, Muttin observes.
Muttin believes that improving visibility to PPE, which experienced seemingly insatiable demand during the last 14 months, can be achieved today. “With more consistent capture of product identification data, it becomes easier to track and understand PPE throughout a healthcare system, even across the industry and globe,” he insisted. “Accurate demand planning – and supplier risk analysis – become reality with consistent application of product identification data.”
But Muttin cautions about persistent challenges to demand planning efforts that include a “vast array of suppliers based outside our traditional boundaries, with their own PPE requirements, and political situations that influence exporting abilities.” This can include a container ship, for example, that runs ashore and blocks a canal used in global shipping routes.
“Consistent, global product identification builds greater visibility to these suppliers, while allowing providers to understand opportunity and risk,” he noted. “For accurate demand planning at the local level, an organization has to connect in real time to the number of COVID-19 cases, in a particular geography, down to the ZIP code level.”
See also:
Using drug, supply data standards to make MVPs out of MVCs
Pharma’s got data standards game so what’s med/surg’s excuse?
In terms of supply data standards adoption and implementation, few legitimately can doubt or even question how far along the pharmaceutical industry is when compared to the medical/surgical supply industry.
Might the COVID-19 vaccination process – from manufacturer through distributor through administration site to the patient – serve as something of a motivator to showcase definitively the benefits of supply data standards adoption and implementation? If anything, experts contend the process represents an active case study to test and implement solutions for the larger industry.
“The medical device industry has made significant progress implementing GS1 Standards to meet requirements of the FDA’s Unique Device Identification rule (UDI), similar to the pharmaceutical industry’s DSCSA. Most UDI deadlines for medical devices have passed to be properly bar-coded with unique product identifiers (GTINs) and other standard supply chain data. With an enforcement delay last year, Class I devices have until September 2022 to meet this regulatory obligation. Class II and Class III devices are already properly identified in accordance with the rule.
“Class I medical devices are the last category required to meet the standard, because they are deemed to pose the lowest risk to patients and include a very wide universe of qualifying products. PPE is an example of a Class I medical device, for example. Currently more than 2.6 million medical device product identifiers have been uploaded to the FDA’s Global Unique Device Identification Database (GUDID), and that number is expected to double when all Class I devices are added.
“Both pharmaceutical and medical device industry segments are making notable progress in adopting and implementing standards and both are reporting transformative benefits.”
Angela Fernandez, Vice President Community Engagement, GS1 US
“There is incredible potential in the expansion and use of supply data standards to mitigate many of the issues that came to light in the early days of the pandemic, and much we can learn from pharma.
“GLNs can be used to track the dispersal of products across the entire supply chain – like how they will be used in EPCIS for pharma – allowing us to quickly locate and transfer or redirect PPE to critical areas most in need. Production Information (PI) stored in UDI can help us track device expiration dates and lot/serial numbers to prevent the use of expired, recalled and counterfeit product.
“Operational use of supply data standards will rely on interoperability, so it is critical that we look to solution providers (ERP, EHR, and third-party applications) to ensure that their systems are able to utilize supply data standards and exchange them with other systems.”
Carl Gomberg, Lead Solution Analyst, ITS Cost Management, Premier Inc.
“We need transparent and rigorous implementation of Unique Device Identification (UDI) for medical supplies, used as ubiquitously as NDCs are used with pharmaceuticals. Without consistent application of UDI, we will continue to see the failures and gaps in our supply chain systems and processes.
“One of the biggest challenges still in the healthcare system is that legacy technology does not enable business intelligence, and we still deal with gaps between supply chain and clinical data, which create inconsistent results. The road to system data sharing and interoperability is a long one and with so much data residing in separate systems, we need to access available technology and methodologies that will extract data and make it actually usable. For example, data lakes are now being used, creating secure locations where uncleansed and unstructured data can be structured and analyzed, making it newly consumable and creating greater business intelligence.
“Assimilating, understanding this data will help reduce the risks inherent in the supply chain. Let’s use the technology available today to overcome system and data gaps. The inflection point of leveraging data standards to digitally identify both people and products has already happened. Let’s not waste the opportunity to learn and improve. We have the capability today to use enhanced data and analytics and improve clinical and supply chain alignment, in turn delivering better care to patients and business performance for our organizations.”
Ashok Muttin, Founder & CEO, SupplyCopia
“The pharmacy supply chain is leading the way in how they are able to reconcile everything back to the patient via the EHR. With data standards in place, this provides a better backdrop for visibility as the number of “Mass Vaccination Clinics/Centers” (MVCs) are growing at an astounding rate. As demand drops in the coming months, reporting will also help mitigate the bullwhip effect. Data standards play a pivotal role in that bilateral supply/demand chain information exchange, giving both parties the tools needed to produce and move exactly what is needed.
“This is where we, as supply chain leaders, must pivot and think differently in our areas. Reimagining how business systems, including the ERP and EHR, integrate and communicate to be able to adapt to demand is not only operationally savvy, [but] it has a very real impact on consistent quality of patient care. Ultimately, it all comes down to effective supply chain management. End-to-end visibility is not the destination, but the means. Being able to see your bottlenecks, stockouts, waste, usage, demand, lead times, etc. with transparency is the holy grail of our business. Making sure that the clinician has everything she needs to deliver care to her patients becomes a lot more manageable when the data thread extends from cradle to grave.”
Carrie Gorman, Account Executive, Healthcare, Tecsys Inc.
“The pharmaceutical industry has embraced and shown the benefits of supply data standards. The med/surg industry sees it, and many are taking steps to further that standard usage along. Vizient itself continues to embrace, train, use and promote those standards.
“While the circumstances of COVID are unique, the overarching theme of supply chain disruptions repeatedly occurs, especially in healthcare. Prior to the pandemic, the supply chain had repeatedly faced severe disruption — from hurricanes in Puerto Rico to fires in California and other unanticipated events. Each time these disasters hit without notice, immediately and dramatically, and each time, we recognize that we need more transparency and more visibility to anticipate weaknesses and build in redundancy. Then, the crisis of the moment goes away and that need, while never disappearing, becomes drowned out by the noise of day-to-day operations. While the disruptions caused by the pandemic have been difficult to work through, we can apply the lessons learned to craft a better infrastructure with consistent supply data standards.”
Carl Henshaw, Director, Standards Implementation, Vizient
“The vaccine distribution, though not perfect, highlighted the possibilities and benefits of enhanced visibility and transparency among suppliers, distributors and healthcare providers, with data standards as the common language across all parties. Imagine being able to understand demand across the supply chain and adjust and optimize manufacturing and delivery based on the most up-to-date data. However, it also took a degree of government coordination and reporting mandates to achieve a high level of coordination and traceability across the supply chain.”
Keith Lohkamp, Senior Director, Industry Strategy, Workday
“In the U.S., pharmaceuticals have long been under the requirements for item identification and lot tracking. Since the promulgation of the GS1 standards, these prior standards (e.g., NDC, PDMA) can be accommodated within the GS1 framework. There are significant advantages to the medical/surgical industry to fully implement these standards and compliance is already high and growing. Item identification, lot and serial numbers, pack levels and other information can be encoded in a standard way and represented using the bar-code symbology (or RFID) that makes the most sense for the physical packaging involved.”
Chris Caulfield, Vice President, Temptime Operations, Zebra Technologies
Rick Dana Barlow | Senior Editor
Rick Dana Barlow is Senior Editor for Healthcare Purchasing News, an Endeavor Business Media publication. He can be reached at [email protected].