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Alerts and Updates

CDC Updates Interim COVID-19 Vaccine Allocation Recommendations

December 23, 2020

CDC Updates Interim COVID-19 Vaccine Allocation Recommendations

December 23, 2020

Read below

Each state is in charge of setting and implementing its own respective vaccination plan and protocol. 

At an emergency meeting on December 20, 2020, the CDC’s Advisory Committee on Immunization Practices updated its COVID-19 vaccine allocation recommendations based on limited vaccine supply by specifying the populations for the second and third subphases of the initial vaccine rollout: Phase 1b and Phase 1c. The recommendations have been adopted by the CDC director and became official as of December 22, 2020. Accordingly, the current recommendations for the first phase are as follows:

Phase 1a: Healthcare personnel and long-term care facility residents;

Phase 1b: Persons over the age of 75 years and frontline essential workers;

Phase 1c: Persons 65-74 years old, persons 16-64 years old with high-risk medical conditions and other essential workers.

The following are considered frontline essential workers for Phase 1b: firefighters, police officers, corrections officers, food and agricultural workers, Postal Service workers, manufacturing workers, grocery store workers, public transit workers, those who work in the education sector (teachers and support staff) as well as day care workers.

As States Begin Distribution of Vaccines, What Is Your State’s Allocation Plan?

Each state is in charge of setting and implementing its own respective vaccination plan and protocol. This week, states throughout the country began vaccinating individuals according to their plans. Previously, the CDC issued its “COVID-19 Vaccination Program Interim Playbook for Jurisdiction Operations” to provide interim guidance for states and other governmental entities on how to plan and implement vaccination programs within their jurisdictions. The playbook emphasized that immunization with a safe and effective COVID-19 vaccine is a critical component of the United States’ strategy to reduce COVID-19-related illnesses, hospitalizations and deaths, and to achieve a fully functioning society. In practical terms, the collective goal of the vaccination programs is simple: Vaccinate all people in the United States who want to be vaccinated.

Recognizing early on that, at least initially, there would likely be a limited COVID-19 vaccine supply, the CDC recommended that each jurisdiction implement a three-phase approach to distribution of the vaccination as follows:

Phase 1

Due to the scarcity of the vaccine, concentrate efforts on reaching the following populations: those critical to the pandemic response; those providing direct care to COVID-19 patients; those maintaining societal function; and those at greatest risk for developing severe illness from COVID-19. Ensure the selected vaccination locations can serve those populations, manage cold chain requirements and meet reporting requirements for vaccine supply and uptake. Because the vaccine is expected to be most scarce during this phase, jurisdictions are encouraged, as necessary, to come up with appropriately prioritized subsets of populations for Phase 1, e.g., 1a, 1b, 1c, etc.

Phase 2

A large number of vaccine doses are expected to be available. Jurisdictions should therefore focus on ensuring access to vaccine for all critical populations who were not vaccinated in Phase 1, as well as for the general population. Provider networks should be expanded during this phase.

Phase 3

Once there is sufficient supply of vaccine doses for the entire population (surplus of doses), jurisdictions should focus on ensuring equitable vaccination access across the entire population. They should monitor vaccine uptake and coverage; reassess their strategy to increase uptake in populations or communities with low coverage.

Following such recommendations, each state has developed its own proposed vaccination plan. For the latest on how your state is prioritizing specific populations, review your state’s proposed plan, which is summarized in the “Proposed State COVID-19 Vaccination Plans - Executive Summary for Each State” section.

The proposed or “interim draft” plan for your state can be found in the “Proposed State Covid-19 Vaccination Plans – Detailed Plan for Each State” section.

Given that each state’s vaccination plan is relatively fluid and subject to change with little or no notice, employers should regularly and carefully examine their state’s policies to ensure they are in compliance with applicable vaccination guidelines and following CDC recommendations when in doubt.

About Duane Morris

Duane Morris has created a COVID-19 Strategy Team to help organizations plan, respond to and address this fast-moving situation. Contact your Duane Morris attorney for more information. Prior Alerts on the topic are available on the team’s webpage.

For More Information

If you have any questions about this Alert, please contact Brad A. Molotsky, Sharon L. Caffrey, C. Todd Norris, Morgan L. Swing, any member of the COVID-19 Strategy Team or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.