Alliance to ACIP: Drop Shared Decision-Making and Lower Age-Based Recommendations to Promote Equity

The following statement was made today by Alliance Senior Vice President of Health Education & Advocacy Lindsay Clarke, JD, at the Centers for Disease Control & Prevention (CDC) Advisory Committee on Immunizations Practices (ACIP) Meeting. The livestream is available.

Good afternoon. My name is Lindsay Clarke and I serve as the Senior Vice President of Health Education & Advocacy at the Alliance for Aging Research. Thank you for this opportunity to comment.

Our main message today is this: When the ACIP delays a vote because they think they need more data, the committee is inadvertently hampering vaccine data collection.

This is because public and private payers generally require the FDA’s approval and an explicit ACIP recommendation before they will cover and pay for any new vaccine. This makes more data collection on new vaccines improbable if they’re not being covered and paid for.

With that in mind, here is what we’d like to see ACIP vote on without delay:

1. ACIP should get rid of its RSV and pneumococcal vaccine shared clinical decision-making recommendations for older adults. A report released yesterday by Champions for Vaccine Education, Equity and Progress finds that SCDM vaccine recommendations create complex and unnecessary access hurdles, particularly for underserved communities. You can find the report at cveep.org.
2. There are two FDA-approved RSV vaccines for use in adults ages 60 and older. We would like to see ACIP vote on a universal RSV vaccination for all adults ages 60 and older.
3. Additionally, ACIP should vote to recommend the one RSV vaccine that received FDA approval for expanded use in adults ages 50 and older. We appreciate the CDC’s commitment to bridge vaccine equity gaps, and a 50+ RSV vaccine recommendation would be an important first step. According to the CDC’s own RSV-Net data, every year an estimated 42,000 adults ages 50 to 64 years old are hospitalized due to severe complications from RSV. The data suggest that earlier—and higher—rates of asthma, congestive heart failure, or COPD in underserved communities leads to earlier RSV onset and higher risk of hospitalization and severe outcomes, including deaths. We encourage ACIP to consider data on the two RSV vaccines separately, and not delay consideration of a reduced age recommendation.
4. Similarly, ACIP should vote on a universal pneumococcal vaccine recommendation for adults ages 50 and older. CDC data presented three years ago at the June 2021 meeting showed that an age-based recommendation starting at age 50 could address racial disparities in pneumococcal disease risk and vaccine uptake and provide cost savings.
5. We ask you to please continue to support, and vote on, a preferential recommendation for enhanced flu vaccines.
6. And last, please vote as soon as possible after the FDA approves or authorizes the 2024-2025 COVID-19 vaccines. We would like to see updated vaccines available in August on the same timeframe as annual flu vaccines.

We appreciate the ACIP and the excellent team at the CDC.

Thank you.