Vaccinate Your Family Provides Oral Comments to the National Academies of Science Engineering and Medicine on the Discussion Draft of the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine

September 02, 2020 – My name is Amy Pisani and I serve as the Executive Director of Vaccinate Your Family (VYF).

Thank you for the opportunity to offer comments today. This National Academies Committee has taken on the tremendously important – and delicate – issue of allocating future COVID-19 vaccines equitably. The initial framework is moving in the right direction, particularly as it builds from past experience and existing distribution systems.

Vaccinate Your Family is a national nonprofit organization committed to protecting people of all ages from vaccine-preventable diseases. For nearly 30 years, our organization has been at the forefront of efforts to educate the public about the critical importance of timely vaccinations and to increase confidence in the safety and efficacy of vaccines. Our organization has helped to shape vaccine policies that have made lasting improvements to the vaccine infrastructure of this nation and we will continue to work with our immunization partners to support systemic changes to improve the vaccination rates of children and adults, who experience significant disparities in coverage.

While protecting everyone against COVID-19 with a vaccine will not be possible in the immediate future, we are hopeful that SARS-COV2 will soon be on the list of viruses against which the world is protected through lifesaving vaccines.

Vaccinate Your Family is immensely grateful for the thoughtful draft framework for equitable COVID-19 vaccine distribution created by this committee.  We support the principle of “equal regard” for all individuals and urge the nation to extend this to include the prioritization of high-risk health workers throughout the globe.  We also appreciate the thorough efforts of this Committee to gather learnings from past pandemics to apply to the current crisis.

As the world is now aware, COVID-19 has disproportionately impacted adults over the age of 65, people of all ages with underlying health conditions, and the economically disadvantaged. Combined, these groups account for a large portion of the world’s population. The same  populations who have had severe outcomes from COVID-19, including those who suffer from diabetes, heart disease and a variety of lung conditions, are also at higher risk from other infectious diseases for which we have vaccines including influenza, pneumonia, shingles and whooping cough.

VYF agrees with the Committee’s view that “Fundamental health inequities in COVID-19 and in other health conditions are rooted in structural inequalities, racism, and residential segregation. Any vaccine allocation scheme designed to reduce COVID-19 risk must explicitly address the higher burden of COVID-19 experienced by the populations affected most heavily, given their exposure and compounding health inequities. Mitigating those health inequities is, therefore, a moral imperative of an equitable vaccine allocation system.”

While there have been devastating consequences from this pandemic, it is our hope that the public’s awareness of the dangers of certain underlying medical conditions will drive the development of new partnerships between public health and community organizations, patient advocacy groups, and specialized health associations to increase awareness of the critical importance of COVID-19 and other vaccinations, and to eliminate health disparities.

We urge policymakers to review the background information in this report and take immediate steps to overcome the challenges faced by adults who do not have full coverage for vaccinations under their health plans, Medicaid or Medicare. We support the Committee’s draft recommendation to develop an emergency infrastructure program for adults based on the remarkably successful Vaccines for Children program, which was created in 1993 as part of the Omnibus Budget Reconciliation Act and has been credited with nearly eliminating racial vaccine disparities among children.

In order to increase public confidence in the prioritization plan, we wish to stress the importance of making the decisions of this Committee readily accessible to the public. We appreciate that the Committee recognizes the need to ensure the framework is easily understood by all audiences and that the vaccine is not only distributed equitability, but also perceived as equitable by populations who are “socioeconomically, culturally and educationally diverse, and who have distinct historical experiences with the health system”.

Therefore, we urge the National Academies and government agencies to engage traditional and non-traditional vaccine and health communication partners to further share these recommendations in the media, online and through organizations with direct access to the public.

People in the U.S. must understand the process for developing the framework, as well as the framework itself, in order to feel confident that the new COVID-19 vaccine will be distributed fairly and equitably. The public health community stands ready to share the deliberative process used by this Committee as you offer your recommendations to the ACIP and the public.

Unfortunately, some of the people who will be prioritized for COVID-19 vaccination may be hesitant about the vaccine’s safety and efficacy. This could be for a variety of reasons including general hesitancy toward vaccination or concerns about the speed with which the COVID vaccines are being developed. Efforts to communicate about this framework must therefore be complemented with ongoing conversations about how COVID-19 vaccines are being developed and information about the systems in place to monitor vaccine safety and efficacy in the U.S.  The purpose and historical success of each of these safety systems should be broadly shared with the public.

Once again, Vaccinate Your Family appreciates the Committee’s thoughtful allocation criteria, which reflect some very difficult, but critical considerations to ensure that those at greatest risk of contracting and spreading COVID-19 are prioritized to protect the entire public. The considerations outlined in this report reflect this Committee’s vast scientific and social justice expertise we are confident that the prioritization decisions included careful deliberation of the critical factors that will ensure equitable distribution that will help mitigate the spread and dangerous complications of COVID-19.

As we await the Committee’s final report, Vaccinate Your Family will focus our efforts on ensuring that every individual who seeks a future vaccine has equal access to immunizations.

Thank you

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