From Christina Hildebrand <[email protected]>
Subject [AVFCA] Action Alert: Comment on HHS National Vaccine Plan (NVP) by 5pm 10/24/19
Date October 23, 2019 8:59 PM
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HHS is updating their national vaccine plan for 2020 and are requesting public comments, before 5pm EST tomorrow October 25, 2019. Sorry for not getting this to you sooner, but we were only alerted about it this morning. More details below, but here is goal is to solicit specific xxxxxxrmation regarding the priorities, goals, and objectives in the next iteration of the National Vaccine Plan, remaining gaps, and stakeholder perspectives for the 2020-2025 timeframe.

Action Alert: Please email <mailto:[email protected]> [email protected] with comments in response to the following questions:
1. Priorities for the 2020 National Vaccine Plan during 2020-2025. What do you recommend as the top priorities for vaccines and immunizations in the United States? Why are these priorities most important to you? [Provide up to 2 pages to answer these questions]
2. What changes should be made to the 2010 National Vaccine Plan to make it more current and useful? This could include changes to the goals, objectives, strategies, activities, indicators, and other areas of the plan. Which components of the 2010 National Vaccine Plan worked well and should be maintained? [Provide up to 2 pages to answer these questions]
3. What are the goals, objectives, and strategies for each of your top priority areas? Are there any goals in the current strategy that should be discarded or revised? Which ones and why? [Provide up to 2 pages to answer these questions]
4. What indicators can be used to measure your top priorities and goals? Are there any indicators in the 2010 National Vaccine Plan or the National Adult Immunization Plan ([link removed]​sites/​default/​files/​nvpo/​national-adult-immunization-plan/​naip.pdf <[link removed]> ) that should continue to be used? If so, which ones, and why? [Provide up to 2 pages to answer these questions]
5. Identify which stakeholders you believe should have responsibility for enacting the objectives and strategies listed in the 2020 National Vaccine Plan, as well as for any new objectives and strategies you suggest.
6. Specifically identify roles that you or your organization might have in the 2020 National Vaccine Plan. [Provide up to 2 pages to answer these questions].

Please be sure to make it sound polite and professional so it is taken seriously. Here are some things you could include:
* Science and/or religious arguments for why exemptions are a necessity for all vaccine programs. Reference package inserts, Vaccine injury compensation program, VAERS, genetic research. For religious reference vaccine ingredients.
* Request research into vaccine failure, that we are seeing with Measles, Mumps and Pertussis, where the majority of those getting the diseases are fully vaccinated.
* Request vaccine injury research of the entire cumulative vaccine program
* Request research into the 54% of children have chronic illnesses and the rising level of autism, and the role the increase in vaccines play in those. Again the entire vaccine program rather than just one vaccine or one ingredient.
* Demand that the vaccine manufacturers become liable for their product and remove the 1986 national vaccine injury act.
* There is a clear goal for adult vaccination. Here is the adult vaccination schedule that they would want to mandate:
[link removed] Comment on why these should not be mandatory.
* Vaccine "Use Monitoring" is a troubling term in the rapidly progressing Big Data/Digital/Mobile/Tech Age. What will this mean? Nano-trackers inside vaccines themselves? Bar/QR Codes? Implants like they have in Sweden? Monitoring via Mobile Phones?
* Comment on xxxxxxrmed choice and being able to make a fully xxxxxxrmed decision with one’s doctor not just be coerced into vaccination.

More xxxxxxrmation (copied below from [link removed])
SUMMARY:
The development of a National Vaccine Plan (NVP) was mandated by Congress as a mechanism for the Director of the National Vaccine Program (as delegated by the Assistant Secretary for Health) to communicate priorities for achieving the Program's responsibilities of ensuring adequate supply of and access to vaccines and ensuring the effective and optimal use of vaccines.

The most recent NVP, released in 2010, provided a comprehensive 10-year national strategy for enhancing all aspects of the plan, including vaccine research and development, supply, financing, distribution, and safety; xxxxxxrmed decision-making by consumers and health care providers; vaccine-preventable disease surveillance; vaccine effectiveness and use monitoring; and global cooperation ([link removed]). To help xxxxxxrm the development of the National Vaccine Plan 2020, HHS is issuing a Request for xxxxxxrmation (RFI). The RFI will solicit specific xxxxxxrmation regarding the priorities, goals, and objectives in the next iteration of the NVP, remaining gaps, and stakeholder perspectives for the 2020-2025 timeframe.

SUPPLEMENTARY xxxxxxRMATION:
With U.S. vaccination rates above 90% for many childhood vaccines, most individuals have not witnessed firsthand the devastating illnesses against which vaccines offer protection, such as polio or diphtheria.

According to a recent study, routine childhood immunizations among U.S. children born in 2009 will prevent 20 million cases of disease and 42,000 premature deaths, with a net savings of $13.5 billion in direct costs Start Printed Page 50051and $68.8 billion in total societal costs.[ <[link removed]> 1]

In contrast, adult vaccination coverage rates have remained persistently low, with only modest gains for certain populations in the past few years.[2 <[link removed]> ] As a result, the standards for adult immunization practice were updated in 2014 to promote integration of vaccines into routine clinical care for adults.[3 <[link removed]> ]

Despite the widespread availability of effective vaccines, vaccine-preventable diseases (VPDs) remain a significant public health challenge. In particular, rates of non-medical exemptions for childhood vaccines are increasing,[4 <[link removed]> ] and there have been recent measles outbreaks in the U.S.[5 <[link removed]> ] and globally, due to growing vaccine hesitancy and coverage levels below the threshold needed for herd immunity.

With an estimated cost of $20,000 per case of measles to the public sector in 2016,[6 <[link removed]> ] the economic consequences of this and other VPDs, as well as the health consequences, are significant. Furthermore, few adults in any age group are fully vaccinated as recommended by the Advisory Committee on Immunization Practices.

Large disparities in vaccine coverage by race/ethnicity persist, with African Americans, Hispanics, and Asian Americans lagging behind whites in nearly all vaccination coverage rates.[7 <[link removed]> ] VPDs such as pertussis and hepatitis B continue to take a heavy toll on public health,[ <[link removed]> 8] with 18,975 cases of pertussis and 3,409 (22,000 estimated) cases of hepatitis B infections reported in the United States in 2017.[ <[link removed]> 9 10] In light of these challenges, strengthening the vaccine and immunization enterprise is a priority for HHS.

The 2010 National Vaccine Plan ([link removed]​sites/​default/​files/​nvpo/​vacc_​plan/​2010-Plan/​nationalvaccineplan.pdf <[link removed]> ) and the associated implementation plan ([link removed]​sites/​default/​files/​nvpo/​vacc_​plan/​2010-2015-Plan/​implementationplan.pdf <[link removed]> ) have played an important role in guiding strategies and allocations of resources with respect to vaccines and vaccination. However, since the publication of the 2010 National Vaccine Plan, there have been many changes in the vaccine landscape.

To respond to the public health challenges of VPDs, OIDP in collaboration with other federal partners is leading the development of the 2020 National Vaccine Plan. This updated plan will recommend vaccine strategies across the lifespan and guide priority actions for the period 2020-2025. To develop this plan, HHS, through OIDP, seeks input from subject matter experts and nonfederal partners and stakeholders such as health care providers, national professional organizations, health departments, school administrators, community-based and faith-based organizations, manufacturers, researchers, advocates, and persons affected by VPDs.

This request for xxxxxxrmation seeks public input on strengthening and improving the nation's response to VPDs and strategies to address infectious diseases through vaccination. The 2020 National Vaccine Program requests xxxxxxrmation in five broad areas. Responders may address one or more of the areas below:

1. Priorities for the 2020 National Vaccine Plan during 2020-2025. What do you recommend as the top priorities for vaccines and immunizations in the United States? Why are these priorities most important to you? [Provide up to 2 pages to answer these questions]

2. What changes should be made to the 2010 National Vaccine Plan to make it more current and useful? This could include changes to the goals, objectives, strategies, activities, indicators, and other areas of the plan. Which components of the 2010 National Vaccine Plan worked well and should be maintained? [Provide up to 2 pages to answer these questions]

3. What are the goals, objectives, and strategies for each of your top priority areas? Are there any goals in the current strategy that should be discarded or revised? Which ones and why? [Provide up to 2 pages to answer these questions]

4. What indicators can be used to measure your top priorities and goals? Are there any indicators in the 2010 National Vaccine Plan or the National Adult Immunization Plan ([link removed]​sites/​default/​files/​nvpo/​national-adult-immunization-plan/​naip.pdf <[link removed]> ) that should continue to be used? If so, which ones, and why? [Provide up to 2 pages to answer these questions]

5. Identify which stakeholders you believe should have responsibility for enacting the objectives and strategies listed in the 2020 National Vaccine Plan, as well as for any new objectives and strategies you suggest.

Specifically identify roles that you or your organization might have in the 2020 National Vaccine Plan. [Provide up to 2 pages to answer these questions].

The xxxxxxrmation received will xxxxxxrm the development of the 2020 National Vaccine Plan.

Dated: September 9, 2019.
Tammy R. Beckham,
Director, Office of Infectious Disease and HIV/AIDS Policy.

Footnotes
1.  Zhou F et al. Economic evaluation of the routine childhood immunization program in the United States, 2009. Pediatrics. 2014; 133: 1-9.
Back to Citation <[link removed]>
2.  [link removed]​vaccines/​imz-managers/​coverage/​adultvaxview/​pubs-resources/​NHIS-2017.html <[link removed]> .
Back to Citation <[link removed]>
3.  National Vaccine Advisory Committee. Recommendations from the National Vaccine Advisory Committee: standards for adult immunization practice. Public Health Rep. 2014;129:115-23.
Back to Citation <[link removed]>
4.  Omer, S. et al. Nonmedical exemptions to school immunization requirements: secular trends and association of state policies with pertussis incidence. JAMA. 2006;296(14):1757-1763.
Back to Citation <[link removed]>
5.  [link removed]​measles/​cases-outbreaks.html <[link removed]> .
Back to Citation <[link removed]>
6.  Lo NC, Hotez PJ. Public Health and Economic Consequences of Vaccine Hesitancy for Measles in the United States. JAMA Pediatr. 2017;171(9):887-892. doi:10.1001/jamapediatrics.2017.1695.
Back to Citation <[link removed]>
7.  Lu PJ et al. Racial and Ethnic Disparities in Vaccination Coverage Among Adult Populations in the U.S. Am J Prev Med. 2015;49(6 Suppl 4):S412-S425. doi:10.1016/j.amepre.2015.03.005.
Back to Citation <[link removed]>
8.  [link removed]​vaccines/​pubs/​pinkbook/​downloads/​appendices/​e/​reported-cases.pdf <[link removed]> .
Back to Citation <[link removed]>
9.  [link removed]​centers-programs/​vaccine-education-center/​global-immunization/​diseases-and-vaccines-world-view <[link removed]> .
10.  Schillie et al. Prevention of Hepatitis B Virus Infection in the United States: Recommendations of the Advisory Committee on Immunization Practices. MMWR. 2018;67(1):1-31.
Back to Citation <[link removed]>

Christina Hildebrand
President/Founder
A Voice for Choice Advocacy, Inc.
www.avoiceforchoiceadvocacy.org <[link removed]>
408 835 9353


WWW.AVOICEFORCHOICEADVOCACY.ORG <[link removed]>
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