October 27, 2016
Catrice Williams, Office of the General Counsel
Department of Public Health
250 Washington Street
Boston, Massachusetts 02108
Re: Proposed Amendment to 105 CMR 130.000
Dear Ms. Williams:
On behalf of GlaxoSmithKline, thank you for the opportunity to submit comments in support of
proposed amendments to 105 CMR 130.000. We write in support of a proposed amendment to
this rule that would require the Commissioner of Public Health to adopt regulations requiring
hospitals to offer prior to discharge, immunization against influenza to all inpatients 65 years of age
and older during influenza season. We believe that the amendment proposed by the
Massachusetts Health and Hospital Association (MHA) would advance the goal protection and
health for the elderly.
Specifically, we support the proposal to insert at the end of 105 CMR 130.325 within a new subpart
(J) as follows:
a. (J) Consistent with guidelines issued by the Department, each hospital shall ensure that
all patients 65 years of age and older are offered an influenza vaccination when receiving
services, as medically appropriate.
Influenza viruses can cause disease among persons in any age group, but rates of severe
outcomes from influenza disease are highest among children and older adults. Rates of serious
illness and death are highest among persons aged >65 years, children aged <2 years, and persons
of any age who have medical conditions that place them at increased risk for complications from
influenza.1 It is estimated that 80 to 90 percent of seasonal flu-related deaths and 50 to 70 percent
of seasonal flu-related hospitalizations in recent years have occurred in people 65 years and older. 1
The best way to prevent flu is through vaccination. The CDC recommends that everyone 6 months
of age and older get a seasonal flu vaccine each year soon after it becomes available, and by
October if possible. Vaccination is especially important for people 65 years and older because they
are at high risk for complications from flu. Unfortunately, only 64 percent of Massachusetts
residents aged 65 years and older received the flu vaccine during the 2013-2014 flu seasons. 2 This
leaves a significant number of seniors at risk for hospitalization or even death due to influenza.

1 Centers for Disease Control and Prevention (CDC), Estimated Influenza Illnesses and Hospitalizations Averted by
Vaccination — United States, 2014–15 Influenza Season, Atlanta, GA: US Department of Health
and Human Services, CDC; 2015. Available at http://www.cdc.gov/flu/about/disease/2014-15.htm.
2 MDPH, Influenza Vaccination Rates in Massachusetts. Available at http://www.mass.gov/eohhs/docs/dph/cdc/flu/newflu-recs.pdf

October 25, 2016

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 This proposed amendment would protect hospitalized older adult patients by ensuring that they
have the opportunity to receive a vaccination against influenza disease. We strongly encourage the
Department to adopt it. If you have any questions about GSK’s position on this amendment, please
contact Paul Graml, Director, State Government Relations, at paul.c.graml@gsk.com.
Sincerely,

Tanisha Carino
Vice President, US Public Policy

October 25, 2016

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