Alliance to VRBPAC: Consistency is Key to Protecting Older Adults Through Vaccination

The following statement was made today by Alliance President & CEO Sue Peschin, MHS, during the public comment portion of the Vaccines and Related Biological Products Advisory Committee (VRBPAC) meeting:

Good afternoon. I’m Sue Peschin and I serve as President and CEO of the Alliance for Aging Research. The Alliance is one of three co-conveners of the COVID-19 Vaccine Education and Equity Project, or CVEEP—a collective of more than 250 non-profit organizations focused on equitable access to vaccines and treatments. While CVEEP and the Alliance receive funding from sponsor companies, we do not advocate for any particular vaccine.

First, thank you to the FDA and this advisory committee for meeting early enough to allow these updated vaccines, if approved or authorized, to be available in August on a timeframe similar to annual flu vaccines. In 2023, the public—including all those at highest risk of hospitalization and death—didn’t start getting their COVID-19 vaccines until over a month into the respiratory season, and after 83 million flu vaccine doses had already been administered. Unfortunately, that was a missed opportunity to ensure more individuals could be vaccinate for COVID-19 and flu at the same time.

That said, we’re thrilled and grateful to see the coordinated steps taken between the FDA and CDC to better align with the start of the 2024 respiratory season.

For today’s discussion, we put our full confidence in the FDA’s expertise on strain selection and vaccine technology. The FDA acknowledged in today’s briefing documents that there are differences in production timelines between mRNA and protein-based vaccines, with the latter taking longer. However, in addition to timeline considerations, we know that there are people living with rare diseases and compromised immune systems who require protein-based vaccines. Please keep that in mind as you consider how strain selection will impact the availability of different types of vaccines so that all members of the population can be as protected as possible.

More broadly, here’s what we are seeking today:

• The FDA and CDC must use clear and simple COVID-19 vaccine recommendation language that’s as easy to implement as possible. Age-based routine recommendations 6 months and older are critical so that there aren’t delays or confusion in who is eligible for the vaccines. For CDC, please avoid shared clinical decision-making recommendations, which impede access, as we’ve seen with pneumococcal vaccines and are also seeing with the RSV vaccines.  

• Both agencies must also craft simple and consistent messaging on coadministration of vaccines. For example, is it okay for my 83-year-old mom to get the updated COVID-19 vaccine when she gets her annual flu vaccine? What about coadministration and timing for the RSV, pneumococcal, or any other vaccine?

• We also implore both agencies to emphasize the benefits of enhanced flu shots for older adults, and to amplify recently published research in JAMA Internal Medicine on the lifesaving benefits of RSV vaccines. We need to push those who make the big decisions on access and payment to give everyone a fair shot at protection this year.

• To Centers for Medicare and Medicaid Services (CMS) staff that are listening today: CMS must fix longstanding payment issues for vaccine administration in long-term care settings. If skilled nursing facilities and pharmacies had the ability to confidently vaccinate anyone in their purview at any time, and know they’d be reimbursed appropriately, we would see a significant uptick across all recommended vaccines. This also applies to long-term care staff. During COVID-19, many staff were vaccinated alongside the residents during the clinic days at the nursing homes, but that flexibility is long gone. As the saying goes: “Those who forget history are condemned to repeat it.”  

Thank you to this advisory committee for serving as true advisors to the FDA and for respecting and supporting the FDA’s and CBER’s deep expertise in vaccine review. We all have a long way to go together to repair years of misinformation on vaccines, the FDA, and the important process that you are participating in today.

Thank you.