NASEM Draft Framework for Equitable Allocation of a COVID-19 Vaccine

Remarks by Scott Knoer, PharmD, MS, FASHP
CEO/Executive Vice President
American Pharmacists Association
September 2, 2020

Good afternoon. I am Dr. Scott Knoer, Executive Vice President and CEO of the American Pharmacists Association. APhA represents pharmacists in all practice settings, including community pharmacies, hospitals, long-term care facilities, physician offices, clinics, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care, and enhance public health. 

Thank you for providing a draft Framework for the equitable allocation of COVID-19 vaccines. We appreciate the Committee’s recommendation of an evidence-based, phased allocation and prioritization approach to maximize the societal benefit of reducing transmission of coronavirus.  

We strongly urge the Committee to reconsider the placement of pharmacists in Tier 2 in the allocation scheme. Pharmacists belong in Tier 1. Pharmacies and pharmacists in all practice settings are essential front-line health care providers and have been providing COVID-19 and related patient care since the coronavirus first appeared in the United States. We are proud of the tremendous critical efforts that our members have undertaken to help our nation respond to the pandemic and maintain the continuity of care for our patients and communities.

Pharmacists have been on the front lines, working with other members of the health care team and communities:

  • ensuring medication access and availability to support continuous adherence to therapeutic regimens; 
  • expanding the availability of COVID-19 tests, and administering vaccines to protect children, adolescents and adults from vaccine preventable diseases, including the flu; 
  • providing evidence-based information to other health care providers and patients on medications for COVID-19 treatment and symptomatic support; 
  • delivering in-person and telehealth services to patients with chronic conditions in collaboration with other providers; and 
  • compounding drugs to mitigate and prevent shortages.

These essential public health protection efforts provided by pharmacists are critical to advancing the overall health of our nation and ensuring high risk patients, health care providers, and those who support critical infrastructure remain healthy to do their jobs and keep the country open and productive. 

Pharmacists provide direct patient care daily as health care providers and will serve as key immunizers for persons at high risk of transmission in patient care settings and in the community.

Pharmacists are the most accessible health care providers with close to 90% of the U.S. population living within 5 miles of a pharmacy,  including many underserved areas.  And, patients do not need an appointment to see their pharmacist.  Whether inner city, rural, or elsewhere, pharmacists have deep reach and roots within their communities.

More than 360,000 pharmacists have been trained to administer vaccines across the lifespan and stand ready and able to meet the healthcare needs of their patients and communities.   Any successful vaccination plan for the equitable allocation of COVID-19 vaccine(s) must involve all licensed pharmacists and pharmacies. An all-hands-on-deck approach will be needed. 

A pivotal CDC pandemic influenza vaccine study showed that weekly national vaccine administration capacity increased to 25 million doses per week, and the time to achieve 80 percent vaccination coverage nationally was reduced by seven weeks, when pharmacist vaccination capacity was included in the response.

We have 3 recommendations for the Committee to include in the finalized Framework: 

  1. To ensure that pharmacists are able to continue to provide critical care to patients, including administration of COVID-19 vaccine, the Framework must recognize pharmacists in all practice settings in Tier 1 as essential front-line health care providers for priority vaccine allocation and administration. 
    • The Framework identifies “clinicians,” and “other workers in health care settings who meet the Phase 1a risk criteria.” Pharmacists meet 3 of the 4 risk criteria, including: Criterion 1: Risk of Acquiring Infection; Criterion 3: Risk of Negative Societal Impact; and Criterion 4: Risk of Transmitting Infection to Others. Therefore, pharmacists fall in Tier 1, not Tier 2.
  2. To ensure the equitable allocation of COVID-19 vaccines to priority and other populations, APhA strongly urges the Committee’s report include a primary recommendation that ALL licensed pharmacies are given a priority designation in Federal and State vaccine allocation, distribution, and immunization plans. This should include prioritization of ancillary supplies and access to PPE in the delivery of care to patients and protection of our immunizing workforce.
  3. The Committee should recommend that Federal and State vaccine distribution and immunization plans include a fully-funded component for pharmacists and other accessible health care practitioners to conduct coordinated and consistent community-based education and outreach campaigns supporting recommended vaccinations.  These campaigns should focus on eliminating stigma, addressing vaccine hesitancy, and improving prevention and health outcomes for high priority and vulnerable patient populations. 
    • Pharmacists are trusted health care providers and that patient trust will be key in educating and encouraging patients to get vaccinated for COVID-19.  

Thank you again for your efforts. We strongly recommend that the Committee engage the pharmacy community in any ongoing discussions and process evaluations related to vaccine allocation and distribution. The American Pharmacists Association looks forward to continuing to work alongside all of America’s heroic health care workers to defeat COVID-19.  Pharmacists are health care providers in your neighborhood and on health care teams. We are at the front lines and are an essential part of the effort to vaccinate communities and prevent the spread of COVID-19 across the country.