Comments on the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine

Abstract

On September 1, 2020 the National Academies released a draft framework for Equitable Allocation of a COVID-19 Vaccine. In this response, we analyze the proposed framework and highlight several areas.

Among the proposed changes, we highlight the need for the following interventions. The final framework for distribution of COVID-19 vaccines should give a higher priority to populations made most vulnerable by the social determinants of health. It should incorporate more geography-based approaches in at least some of the four proposed phases of vaccine distribution. It should address the possibility of a vaccine being made available through an emergency use authorization (EUA), which we argue should not serve as a basis for widespread distribution of COVID-19 vaccines, and which may not be appropriate at all for the regulatory review of new vaccines. Moreover, it should address potential adjustments to the allocative framework once additional data pertaining to multiple vaccines becomes available, especially by discussing whether steps should be taken to prevent the administration of different vaccines to the same individual. Finally, it should provide guidance on allocation of vaccine in the case of a surplus, and specifically the Committee should specify whether unused doses of vaccine would automatically be allocated to next-level priority populations, and whether that would take place in the same geographical area.

Keywords: COVID-19, vaccines, social determinants of health, racial discrimination, vaccine distribution, FDA, Food and Drug Administration, CDC, Centers for Disease Control and Prevention, emergency use authorization, pandemic, epidemic, equitable allocation, distributive justice