HomeMy WebLinkAbout01.19.21 Letter
From:Pickett, Andy
To:Alpert, Bruce;Bennett, Robin;Clerk of the Board;Connelly, Bill;Cook, Holly;Cook, Robin;Kimmelshue, Tod;
Lambert, Steve;Lucero, Debra;McCracken, Shari;Paulsen, Shaina;Pickett, Andy;Ring, Brian;Ritter, Tami;
Rodas, Amalia;Sweeney, Kathleen;Teeter, Doug
Subject:Letter
Date:Tuesday, January 19, 2021 10:57:31 AM
Attachments:Urgent Local Vaccine Recommendations 1-18-21.pdf
Board Members,
Please see the attached joint letter by CSAC, RCRC, Urban Counties, CHEAC, and HOAC to the
Governor regarding timely reporting, data transparency, and vaccine allocations. It outlines the
challenges counties face, and provides recommendations.
Andy
Máximo A. Pickett
Chief Administrative Officer
Butte County Administration
25 County Center Drive, Suite 200, Oroville, CA 95965
T:
January 18, 2021
The Honorable Gavin Newsom
Governor, State of California
st
State Capitol Building, 1 Floor
Sacramento, CA 95814
RE: Urgent Local Vaccine Recommendations
Local health departments have a critical role in the administration of vaccines and are part of a
broader approach and commitment to equity adopted by the state. This strategy requires strong
leadership, close state-local coordination, and transparency amongst all involved in vaccine
administration. Our associations write today to outline the challenges local health jurisdictions
are facing and provide recommendations that will aid in a more efficient and coordinated effort
–and thus result in vaccinating as many Californians as quickly as possible.
From the local perspective, Counties believe the most critical issue for the state to address is data
transparency and timely reporting, which could improve what we believe tobe asignificant
underreporting of California’s progress to date. Additional challenges include the lack of
transparency regarding allocations among all entities, a slow federal-pharmacy partnership, and
a severe shortage of available doses. As we outline challenges below, we also provide the
following recommendations.
Timely Reporting. Local health departments also believe there are significant data lags and
reporting challenges that result in an underreporting of California’s progress. Some local health
departments have identified providers that have indicated a higher number of doses being
reported than what is being accounted for in the California Immunization Registry (CAIR2)
system. Other jurisdictions have reported that they must reenter data multiple times because
the CAIR2 system is kicking them out. When they attempt to reconcile data, they are being kicked
out as well. This leads to additional workload and administrative burden on vaccinating entities
when attention should be focused on vaccination efforts. Lastly, local health departments have
encountered providers that are not reporting in a timely manner because the system is overly
complicated and burdensome.
Recommendations:
Provide state staff to support the CAIR2 system 24/7.
Audit providers that are reporting low numbers of vaccine being administered to
identify whether the challenges are related to system deficiencies and deploy a team
to support any additional workload being created.
Provide additional training to vaccinating entities on the reporting system.
Institute state level enforcement strategies on providers that do not report after state
level intervention. Can include a state public health order to enter data within 24
hours (similar to the testing directive) and coordination with local health departments
on enforcement.
Data Transparency. Currently all providers that administer vaccines are required to report doses
administered into the CAIR2or the appropriate regional registry. The state requires doses to be
reported within 24 hours of administration, doses in inventory to be reported daily, and for race
and ethnicity information to be submitted for every patient. It is also our understanding that the
data extracted from CAIR2 is what is provided to the federal government to track progress made
in our state. It is important that the state and local health departments have a clear line of sight
as to what is being allocated, received, and administered throughout the state so that we can
identify when there are data inconsistencies and/or when vaccine is not being administered in a
timely manner. This will allow further investigation and identification of the challenges and will
allow for more improvement of the system.
In addition, timely and accurate data supports local health departments in making key decisions
at the local level. For example, because of delays with the federal pharmacy partnership, many
long-term care and congregate living facilities have asked local health departments to step in and
vaccinate their staff and residents. However, local health departments have no line of site as to
the progress being made by CVS/Walgreens and/or how much vaccine is being distributed in their
jurisdictions. In addition, multi-county entities (MCEs) have requested additional vaccine from
local health departments and again, due to a lack of data transparency, it is difficult to assess
whether they are being provided enough vaccine through the MCE process or whether the MCE’s
allocation process needs to be reevaluated.
Recommendations:
Extract the following data from CAIR2 and grant access to local health jurisdictions:
o Doses allocated to, received by, and administered by the federal pharmacy
partnership statewide and by jurisdiction.
o Doses allocated to, received by, and administered by MCEs, both statewide
and by local health jurisdiction. This should be separated by doses provided to
MCEs by the state and doses provided to MCEs by local health departments.
o Doses allocated to, received by, and administered by local health care
partners.
o Doses allocated to, received by, and administered by local health
departments.
Vaccine Allocations. As local health departments strive to ramp up vaccination efforts, local
health departments need assurances that the vaccine allocations will be predictable, will
continue to increase, and will be provided more than one week in advance. Local health
departments currently receive their allocation amounts each week and those allocations change
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based on the supply available and cannot be easily anticipated. This creates uncertainty and
makes planning for an expansion of clinic efforts difficult. Many local health departments stand
ready to increase their capacity at their mass vaccination clinics and/or through their locally
established partnerships but need allocations to be communicated weeks in advance.
Recommendations:
Request that the federal government provide allocation amounts one month in
advance and that the state provide those allocations to the local health departments.
Accountability for all Partners. California’s approach to vaccine administration consists of the
following:
Federal Pharmacy Partnership: California has opted into the Federal Pharmacy Partnership,
where doses that would have otherwise flowed directly to the state to allocate, instead is
allocated by the federal government to CVS and Walgreens to vaccinate long-term care and other
congregate living facilities. To date, very few doses have been administered by these entities, and
local health jurisdictions and individual providers have in some cases stepped in and used their
allocated doses for this population to prevent more illness and death.
Multi-County Entities: The state allocates a portion of California’s doses to multi-county entities
–entities that are in multiple jurisdictions throughout the state (i.e., Kaiser, Sutter, state prisons).
These MCEs are responsible for distributing vaccine to all of their hospitals or facilities in every
jurisdictionin which they operate. However, they are only tasked with vaccinating their members
and do not offer vaccine to the general public, the uninsured, and underserved non-member
populations unless hospitalized.
Local Health Departments: The state allocates remaining doses to California’s 61 county and city
health departments. Local health departments can then allocate doses to enrolled providers in
their jurisdiction or administer the vaccines through their own clinics and point of distribution
sites(PODS). Local health jurisdictions are typically the only entity that may provide vaccinations
to all people who qualify under thestate’s vaccine plan regardless of income, insurance status,
or immigration status. Additionally, local jurisdictions have already identified and mounted
outreach efforts to underserved populations, entered into employer partnerships to inoculate
farmworkers, and remain the only publicly funded and accountable entity with such a critical role
for equitable access to these lifesaving vaccines.
Recommendations:
Support the redirection of vaccines from the Federal Pharmacy Partnership to local
health departments in jurisdictions where the implementation is delayed and local
health departments are supporting the vaccination in those settings.
Hold CVS/Walgreens and MCEs accountable to timely reporting at the local health
jurisdiction level.
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We urge the state to consider theserecommendations and to prioritize thoroughly investigating
and improving the data transparency and reportingbefore modifying the state’s strategy for
distributing vaccine.Improving the allocations should also be a near-term goal and providing a
clear picture of state progress is in the best interest of the state, local jurisdictions, and the people
we all serve.
Counties and local health jurisdictions are committed to drastically improving the state’s
vaccination rates, and in the absence of an adequate supply of doses from the federal
government in the next few weeks, we request that the state prioritize data reporting and
compliance in the meantime. These efforts now will ensure better coordination, equity, and a
more successful vaccination campaign.
Respectfully,
Graham Knaus Paul Smith
Executive Director Senior Vice President, Governmental
Affairs Rural County Representatives
California State Association of
of California
Counties
psmith@rcrcnet.org
gknaus@counties.org
Jean Kinney Hurst Legislative Michelle Gibbons
Advocate
Executive Director
Urban Counties of California
County Health Executives
jkh@hbeadvocacy.com
Association of California
mgibbons@cheac.org
Kat DeBurgh, MPH Executive
Director
Health Officers Association of
California
deburgh@calhealthofficers.org
Cc: Ana Manasantos, Cabinet Secretary, Office of Governor Newsom
Yolanda Richardson, Secretary, California Government Operations Agency
Dr. Mark Ghaly, Secretary, California Health and Human Services
Dr. Tomás Aragón, Director and State Public Health Officer, California Department of
Public Health
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