Demand COVID vaccine access at least twice a year for all ages! Public comment to the CDC closes Oct 18th

Make your voice heard and ask the CDC to:

  • Recommend COVID vaccines for all ages and health statuses at least twice a year (spring vaccine access for all) AND
  • Support more frequent updates to the vaccines, adjusted for the latest variants.
    Submit a public comment using our sample language below.

The committee is anticipated to vote on the following topic on day 1 of the meeting (October 23): “Use of additional doses of COVID-19 vaccine in immunocompromised individuals and older adults following an initial dose of 2024–2025 vaccine”

Your comments make a difference. At this committee’s June 2024 meeting, public comments from our community led to the committee’s decision to make fall COVID vaccines available to people of all ages, rather than limiting eligibility to specific risk groups. Please join us in making your voice heard for spring COVID vaccine access for all, and at least twice a year access going forward.

You can also register to give Oral Public Comment at the upcoming online CDC ACIP Meeting October 23-24 at: https://www2.cdc.gov/vaccines/acip/acip_publiccomment.asp

Submit written comments and/or register to make oral comments at the meeting by Friday October 18 at 11:59pm Eastern Standard Time.

It’s important to submit a personalized comment, which can be brief. Ideas for a personalized comment:

  • How you, your family, or your community would be impacted by spring vaccine eligibility being restricted to only high risk groups (such as older age or immunocompromised status)
  • Barriers to vaccination your have faced, particularly if your eligibility was questioned or misinterpreted by a vaccine provider
  • How out-of-pocket costs are a barrier to getting the latest vaccines

Also feel free to take inspiration from or borrow the language in our sample public comment below.

Step-By-Step Submission Instructions:
Step 1. Go to the Regulations.gov to submit your comment.
Step 2. Type in your comment under the field, “Comment.”
Step 3 (optional). Submit a PDF or Word version of your comment under, “Attach Files.”
Step 4. Select either “Individual” or “Anonymous” depending on if you want to share your personal identifiable information that will be publicly available on the Federal Register.
Step 5. If selecting “Individual,” minimally provide your first and last name. If selecting “Anonymous” you can directly submit the comment without sharing your personal identifiable information. Click “Submit Comment.”

Example Comment:

Docket No. CDC-2024-0072-0001

COVID vaccination at least twice a year (at least every six months) must be recommended for people of all ages, regardless of health status. A restrictive approach to eligibility creates undue barriers for vulnerable people and discourages high risk people from getting needed vaccine boosters. People of all ages, including those who are aged 65 and older or immunocompromised, should have the opportunity to receive another COVID vaccine in the spring of 2025.

The vaccine schedule should address waning efficacy in the months following vaccination [1-3] as well as emergence of new SARS-CoV-2 strains by recommending updated vaccination for all ages, at least every six months. Waning efficacy is seen with all COVID vaccine types, and recent research into the biological mechanisms of waning [4] supports that this effect occurs regardless of age or immunocompromised status. Recent vaccination is associated with a lower risk of developing Long COVID following a COVID infection [5] as well as a lower risk of Multisystem Inflammatory Syndrome in children (MIS-C) [6].

The CDC’s clear and unequivocal recommendation of COVID vaccination at least twice a year for all ages will influence recommendations by healthcare providers, and coverage by health insurance. Moreover, it will improve public awareness in people of all ages about the importance of recent vaccination (within the last six months) to provide the best protection as part of a multilayered approach to preventing illness.

The CDC must ensure equitable and affordable access to updated vaccines and prevent limited access because of financial constraints or demographics. The CDC’s Bridge vaccine access program ended in August 2024 [7], leaving many uninsured and underinsured adults without COVID vaccine access. We ask you to advocate for free COVID vaccine access for all of us to reduce barriers and hesitation to vaccination.

References:
1. Link-Gelles R. Effectiveness of COVID-19 (2023-2024 Formula) vaccines. Presented at: FDA VRBPAC Meeting; June 5, 2024. Accessed June 12, 2024. https://www.fda.gov/media/179140/download
2. Wu N, Joyal-Desmarais K, Vieira AM, et al. COVID-19 boosters versus primary series: update to a living review. The Lancet Respiratory Medicine. 2023;11(10):e87-e88. doi:10.1016/S2213-2600(23)00265-5
3. Menegale F, Manica M, Zardini A, et al. Evaluation of Waning of SARS-CoV-2 Vaccine–Induced Immunity: A Systematic Review and Meta-analysis. JAMA Netw Open. 2023;6(5):e2310650. doi:10.1001/jamanetworkopen.2023.10650
4. Nguyen DC, Hentenaar IT, Morrison-Porter A, et al. SARS-CoV-2-specific plasma cells are not durably established in the bone marrow long-lived compartment after mRNA vaccination. Nat Med. Published online September 27, 2024:1-10. doi:10.1038/s41591-024-03278-y
5. Fang Z, Ahrnsbrak R, Rekito A. Evidence Mounts That About 7% of US Adults Have Had Long COVID. JAMA. Published online June 7, 2024. doi:10.1001/jama.2024.11370
6. Yousaf AR. Notes from the Field: Surveillance for Multisystem Inflammatory Syndrome in Children — United States, 2023. MMWR Morb Mortal Wkly Rep. 2024;73. doi:10.15585/mmwr.mm7310a2
7. https://www.cdc.gov/vaccines/programs/bridge/index.html

Full instructions for written and oral comment and meeting information can be found at: https://www.cdc.gov/acip/meetings/

You can also register to give Oral Public Comment at the upcoming online CDC ACIP Meeting October 23-24 at: https://www2.cdc.gov/vaccines/acip/acip_publiccomment.asp
You must register by October 18 at 11:59pm Eastern Standard Time

CDC’s ACIP meeting information on the Federal Register: https://www.federalregister.gov/documents/2024/09/30/2024-22357/meeting-of-the-advisory-committee-on-immunization-practices

Full Statement:

Vaccination with the latest updated vaccines continues to be foundational to a multilayered approach to COVID, providing protection against both acute disease and Long COVID. Far too few Americans have received the latest vaccines. As of October 11, 2024, only 11.2% of all adults and 26.7% of adults aged 65 and older had received an updated 2024-2025 COVID vaccine. Data for children were unavailable at the time of this writing (October 15, 2024). COVID vaccination rates continue to lag behind influenza vaccination rates. As of July 27, 2024, only 9% of adults aged 65 and older received the recommended two doses of last year’s 2023-2024 vaccine.

Vaccine efficacy wanes significantly four to six months following vaccination, making updated vaccination important for all people as COVID continues to spread in our communities. Vaccine approaches that restrict access based on age or risk status put all of us at risk and leave those at high risk of severe consequences of COVID infection confused about whether they qualify to receive additional doses. These high risk patients may also face barriers as vaccine providers misunderstand the guidelines. A more frequent vaccination approach providing vaccination at least every six months as well as frequent updates to match current variants is needed to better protect all of us amid year-round COVID spread.

Recent vaccination is associated with a lower risk of developing Long COVID following a COVID infection as well as a lower risk of Multisystem Inflammatory Syndrome in children (MIS-C). Waning efficacy is seen with all COVID vaccine types, and recent research into the biological mechanisms of waning supports that this effect occurs regardless of age or immunocompromised status.

El CDC’s Bridge Access Program, which previously provided COVID vaccines to uninsured and underinsured adults free of charge, ended in August 2024. The end of this program without replacement coverage puts people at risk, and public health officials must advocate for free vaccine access for all of us, including those who are uninsured and underinsured.

Submitted written comments or registration to make oral comments at the meeting must be received by the CDC no later than October 18 at 11:59pm Eastern Standard Time

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