Advisory Committee on Immunization Practices (ACIP); Notice of Meeting and Request for Comment

See attached file for complete comments & evidence RE: Comments for the June 2020 Meeting of the Advisory Committee on Immunization Practices (Docket No. CDC-2020-0049) To the Advisory Committee on Immunization Practices (ACIP): The Michigan Chapter of the American Academy of Pediatrics (MIAAP) appreciates the opportunity to submit public comment for the ACIP meeting. We have grave concerns about the plummeting rates of childhood vaccinations. In a time where we have all felt vulnerable through this Covid-19 pandemic, it is important for our communities to be reminded that we fortunately have vaccines to protect children from 16 different diseases. This is currently highlighted in a new Center for Disease Control and Prevention report, containing data on vaccine ordering through the Vaccines for Children (VFC) program. The data highlights that from mid-March to mid-April, doctors in the VFC program ordered about 2.5 million fewer doses of all routine non-influenza vaccines and 250,000 fewer doses of measles containing vaccines, compared to the same time period in 2019. This 60-80% drop in immunizations was also noted in the May 8 Morbidity and Mortality Weekly Report (MMWR), and similarly in the May 18 report. This is mostly concerning due to the increased risk and potential for outbreaks, placing our communities at even more risk in the midst of a pandemic. The MIAAP would like to highlight that pediatric practices around the country have been utilizing guidance from health authorities, including from our national organization, the American Academy of Pediatrics (AAP), to ensure safety for families to bring their children to doctor visits, including well-care visits where routine vaccines can be administered. This message needs continued promotion. In addition, as referenced in a letter sent to leaders in Congress by our national academy president Dr. Goza, we would like to ensure that our healthcare system can maintain essential services and adapt to the needs of our nation's children during this public health emergency. A call has been made for Congress to address the severe financial challenges practices are facing. The VFC program is particularly important at a time when unemployment is high and families may lose their health insurance. Yet pediatricians who currently participate in VFC are facing severe financial challenges and do not receive adequate payment for administering vaccines to uninsured children. This is a deterrent to both remaining enrolled as a VFC provider and to encouraging new enrollees. We ask that support for providers be granted by providing incentive payments to VFC providers, accompanying the call to action to amend payer reimbursements for proper counseling of families. These actions will help providers keep their facilities open and safely running, while remaining in the program to ensure protection to our communities. Finally, vaccine hesitancy continues to be a growing concern. Vaccine-related counseling takes an increasing amount of time during routine well visits and has driven the rise of "alternative" (delayed) vaccine schedules and, in some cases, having a provider elect to not offer vaccines in the office at all, but rather refer patients to the local health department. We are seeing an increasing number of vaccine hesitant families, usually driven by misinformation. This hesitancy will increase the challenge of immunizing children once a Covid-19 vaccine is available. Our pediatric community requests support and assistance in urging Congress to pass the VACCINES Act (H.R. 2862). This is an urgent matter to help increase confidence in vaccines. This bi-partisan bill would provide resources to the CDC to "appropriately monitor vaccine hesitancy and promote vaccine confidence through public messaging campaigns," as Dr. Goza comments. The following critical policy changes, detailed in the attached document, are needed for the VFC program: •VFC Incentive Payments •Increase Regi…