The National Academies of Sciences, Engineering, and Medicine recently released for public comment a discussion draft of a preliminary framework to assist policymakers in planning for equitable allocation of a vaccine against COVID-19. NYHealth provided the following public comments supporting the Academies’ framework, including the mitigation of health inequities, as well as offering recommendations for countering vaccine misinformation and disinformation. 

September 4, 2020

To the National Academies of Sciences, Engineering, and Medicine’s Committee on Equitable Allocation of Vaccine for the Novel Coronavirus:

The New York Health Foundation (NYHealth), a private, independent philanthropy, appreciates the opportunity to submit comments regarding the Discussion Draft of the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine.

Statements of Support

Mitigation of Health Inequities

NYHealth applauds the Committee for the Framework’s grounding in sound ethical and scientific principles. We particularly support the inclusion of “mitigation of health inequities” as a foundational principle. The Framework importantly emphasizes that the staggering racial and ethnic disparities in COVID-19 infections and deaths are not biologically mediated, but result from “structural inequalities, racism, and residential segregation.” As in many other states, minority communities in New York have been disproportionately sickened and killed by COVID-19. Black and Latino residents have died at more than twice the rate of white residents in New York City and at more than three-and-a-half times the rate of white residents in New York State.[1],[2] A vaccine allocation strategy that fails to recognize the structural factors driving these health disparities would ultimately serve to reinforce them. It is vital that the risk-based allocation criteria used in the Framework ethically and effectively prioritize the communities of color hardest hit by the pandemic.

Identification of Local Areas at Risk

Within the population groups included in the four phases of vaccine allocation, the Committee recommends that vaccine access be prioritized for geographic areas identified as vulnerable through the CDC’s Social Vulnerability Index, which is calculated at the census tract level. Localized indexes like this would allow state, local, tribal, and territorial authorities to identify neighborhoods at highest risk for COVID-19 infection that might otherwise be diluted by data collected on a larger geographic scale (e.g., county). The use of localized data is especially important in New York City, where neighborhoods within a few miles of each other have experienced drastically different rates of COVID-19 infections and deaths.[3]

Free Access to COVID-19 Vaccine              

As identified in the Framework, costs associated with COVID-19 vaccine would serve to reinforce disparities by race, ethnicity, socioeconomic status, and immigration status. We support the Committee’s call that Medicare and Medicaid should require free vaccine administration, providers should not charge private plans or consumers, and private insurers and employers should not charge cost-sharing for vaccine administration.


Prepare for Vaccine Misinformation and Disinformation

We recognize that, although this discussion draft outlines the preliminary framework for the equitable allocation of COVID-19 vaccine, the final report will address other aspects of the Statement of Task, including vaccine hesitancy.

The impact of misinformation on vaccine hesitancy and refusal are critical issues that the Committee’s final report must address through mitigation strategies and measures. Misinformation (drawing conclusions from incorrect facts) and disinformation (the deliberate spread of incorrect information) continues to deepen the COVID-19 crisis by eroding trust in public health officials, delaying action by authorities, and jeopardizing infection control strategies.[4] Now, the spread of this same misinformation and disinformation is upending future COVID-19 vaccination efforts. According to a recent poll, 35% of adults say they will not get a coronavirus vaccine if one becomes widely available, even though more than 1,000 people continue to die from the disease every day.[5]

Vaccine misinformation can spread over social and digital media networks at near light speed, often driven by bots, autonomous programs that can spread spam or a virus over the internet. For example, the Public Good Projects (PGP), an NYHealth grantee, uses a software platform called Project VCTR (Vaccine Communication Tracking and Response) that collects publicly available media data related to vaccines.[6] Nationwide, in the last 30 days, it recorded more than 340,000 mentions on social and digital media of negative attitudes related to vaccines.[7] PGP found that messages in opposition to vaccines have more than doubled during the COVID-19 pandemic.[8]

There are strategies to mitigate the spread of this misinformation. Project VCTR’s purpose is to track and contextualize vaccine opposition to inform health organizations and journalists. Supervised by a team of public health practitioners, it functions much like a disease surveillance system, sending out weekly updates on misinformation trends circulating through media sources. In March, PGP also launched Project RCAID (Rapid Communication, Analysis, Interpretation, and Dissemination) to track misinformation related to COVID-19. Tools like this are just one arm of the multidisciplinary strategy needed to combat the deadly impact of misinformation. Should it be helpful to the Committee, we would welcome the opportunity to discuss how the PGP model could be used within the Framework.

This Framework should not underestimate the influence and damage misinformation and disinformation wreaks on public health, especially as it pertains to vaccines. As we enter a critical phase of the COVID-19 pandemic, it is crucial that public health officials and other stakeholders support the creation of tools and strategies that prevent, detect, and respond to misinformation and disinformation and proactively support access to these tools by public health partners.

Given the importance of the issues that will be addressed in the final report, we recommend that the Committee also release an “Interim Final Report” for public comment.

Thank you for the opportunity to provide input on this important matter.

Respectfully submitted,

David Sandman, Ph.D.
President and CEO
New York Health Foundation

[1] New York City Department of Health and Mental Hygiene. “COVID-19: Data.”

[2] New York State Department of Health. “NYSDOH COVID-19 Tracker: Age Adjusted Rate of Fatality COVID-19 Cases per 100,000 by Race/Ethnicity Group.”

[3] New York City Department of Health and Mental Hygiene. “COVID-19: Data.”

[4] Igoe, Katherine. “Establishing the Truth: Vaccines, Social Media, and the Spread of Misinformation.” Harvard T.H. Chan School of Public Health. July 10, 2019.

[5] Gallup. “One in Three Americans Would Not Get COVID-19 Vaccine.” August 7, 2020.

[6] The Public Good Projects. Accessed September 3, 2020.

[7] The Public Goods Project. . “Project VCTR: National Dashboard.” Accessed September 3, 2020.

[8] Byrd, Brian and Joseph Smyser. “Lies, Bots, and Coronavirus: Misinformation’s Deadly Impact on Health.” Grantmakers in Health. July 17, 2020.

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