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NVIC Public Comment - National Vaccine Advisory Committee Meeting, June 5-6, 2012

 Theresa K. Wrangham, NVIC Executive Director

Good morning. My name is Theresa Wrangham and I am the Executive Director for the National Vaccine Information Center. I appreciate the opportunity to offer public comment today.

The National Vaccine Information Center has submitted written requests since the close of NVAC’s February meeting with regard to public access to organizational public comments submitted on the draft Recommendations on Strategies to Achieve the Healthy People 2020 Annual Influenza Vaccine Coverage Goal for Health Care Personnel discussed during February’s NVAC meeting. The Federal Register notice issued for public comment for that effort stated clearly that all public comments submitted would be made available to the public. To date only the comments submitted by individuals have been made available on the NVAC’s website. Organizational comments have not been made available and instead only an Executive Summary has been provided to the public. We request that the organizational comments be made available as required by the Federal Register notice and the Federal Advisory Committee Act (FACA) governing this committee.

Additionally, we have an outstanding request with regard to the public’s ability to purchase the audio recording of February’s meeting and have in the past requested this ability for past NVAC meetings. As you know, NVAC meetings are recorded, but providing these recordings to the public is optional because summary meeting minutes of NVAC meetings are provided fulfill FACA requirements. However, for those of us who routinely listen to these meetings over the phone, summary minutes do not capture the richness of the NVAC’s meetings.

In the spirit of transparency, and as an organization that represents thousands of consumers and regularly participates in public comment during NVAC meetings, we believe it is reasonable that the public be allowed the option to purchase these recordings. We recognize that NVAC is not required to provide recordings and we are not asking that NVAC absorb an additional cost. However, our request for the ability to purchase audio recordings that already exist remains unanswered and we would request that NVAC address our request.

Overall, there would be great benefit to the public if NVAC could post meeting materials on their website prior to meetings, as many times reports given during the meeting move very quickly. For example, Dr Tan’s presentation was very fast paced and difficult to appreciate. We would like to see meeting materials made available to the public as soon as possible.

Finally, I would like to thank Dr. Evans for his report on injury claims received by the VICP and specifically for information provided to the committee today on influenza vaccine injury claims as the leading claim filed with the VICP, as that information was recently questioned in my home state of Colorado during Board of Health rule change hearings. Influenza vaccine injury claims and their subsequent awards are an important consideration with regard to NVAC’s support of employment requirements for health care workers to receive influenza vaccine to meet 2020 Health People Goals, as it is unclear how the associated costs of injury will be handled when vaccine injury is sustained as a result of employment requirements.

These concerns remain largely unaddressed in terms of health care workers ability to draw unemployment benefits subsequent to being fired or resigning from their job for vaccine refusal or having injuries covered under workers compensation where health care workers have complied with these requirements and sustained injury on the job. NVIC noted these concerns in our written public comment submitted to the NVAC earlier this year. As stated in our written comment, NVIC is opposed to any influenza vaccine mandate for health care workers that lack flexible medical, religious and conscientious belief exemptions.

We thank the committee for the opportunity to comment today.

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