Post #896: Has anybody seen our vaccine distribution plan?

Posted on November 21, 2020


I’ve seen it.  I think.  Such as it is.  Maybe.

Before I even try to be amusing about this, take a look at it yourself.  You can read it by following the links on this US DHHS web page.  This is the plan, as released in late September (.pdf).  And this is the “playbook” for executing that plan, released late October (.pdf).

The whole gist of the plan, such as it is, is that vaccines will be distributed through the States.  Presumably, via state public health departments.  You can see an outstanding summary of the status of those State plans via the Kaiser Family Foundation website.   It’s agreed-upon that certain vulnerable or critical populations will get vaccinated first, such as health care workers.  Beyond that, it’s up to the States to determine the distribution routes.

But now, turn to the key table in the Federal plan showing how the vaccine doses will be divided up among the States.  Our allocation plan, as part of the overall distribution plan.  And you will soon find that there is no such table. 

OK, well, fair enough.  Turn back to the table showing the criteria that will be used to make that key State allocation decision.  Will it be a straight per-capita allocation?  Will they allocate doses in proportion to active COVID-19 cases?  Will they allocate based on some measure of lack of (e.g.) staffed hospital beds or staffed ICU beds?

And you will find that there is no such table.  Near as I can tell, there is only a tiny section of vague discussion about factors that might enter into the allocation decision.  (Playbook document, cited above, page 52.)

Allocation of COVID-19 vaccine to jurisdictions will be based on multiple factors, including:
o Critical populations recommended by the Advisory Committee on Immunization Practices (with input from the National Academies of Sciences, Engineering, and Medicine)
o Current local spread/prevalence of COVID-19
o COVID-19 vaccine production and availability

So, sure, there’s a plan for vaccine distribution.  It just doesn’t have any actual details as to where the doses are going to go. 

The pablum listed on the DHHS web page cited above appears to be all the detail there is.  So, which states are going to get how many doses?  The answer is:

Engage with state, tribal, territorial, and local partners, other stakeholders, and the public to communicate public health information around the vaccine and promote vaccine confidence and uptake.

Distribute vaccines immediately upon granting of Emergency Use Authorization/ Biologics License Application, using a transparently developed, phased allocation methodology and CDC has made vaccine recommendations.

I find this unsettling, for several reasons.

First, the FDA is going to approve two vaccines for emergency distribution either this coming week or next week.  So it’s not like there’s a lot of time left to make this distribution decision.  The idea that there’s going to be any public discussion of this has pretty much gone out the window.  Which is a situation that is amenable to abuse.  This looks like it’s going to be a classic back-room, in-the-shadows decision.

Second, back in June, I started speculating on what the US COVID-19 vaccine distribution plan would look like.  And I immediately identified the elephant in the room.  This vital resource was going to be controlled, 100%, by the Federal government, meaning, in practice, the White House.  With all the fairness, competence and transparency that implies (Post #732).

My prediction at that time was that when we finally had vaccines available, we (the US people) wouldn’t even know where the vaccine went.  My bet was that there would never be any publicly-available information on doses obtained and distributed.  And it sure looks like we’re headed in that direction.

Third, in September, I stated my vaccine-distribution criterion for knowing whether or not a vaccine really was effective (Post #800), and predicted that, if effective, the vaccine distribution program would be used for political ends.

If they distribute the vaccine in a reasonable, equitable, and politics-blind manner, I’ll interpret that to mean that it’s not much good. Because if the vaccine is effective, I just can’t see this administration giving up such a great opportunity to reward allies and punish enemies.

And now, sure enough, we’ve had the President threaten to withhold vaccine from the State of New York Because neener-neener boo-boo.  Or something. I never did understand what that was about.

Fourth, there is not one, not two, not three, but four nominally separate Federal agencies who are in charge of this.  That’s DHHS (presumably, the Office of the Secretary), Department of Defense, the US CDC, and Operation Warp Speed. Along with state, territory, and tribal governments.

Fifth, we saw some seemingly rational guidance on who should be prioritized, via the National Academy of Medicine (Post #812).  And there seems to be  general agreement that the list of persons shown there is a reasonable one.  But, in fact, the CDC isn’t following that guidance, but instead has substituted its own list in its October “Playbook”.  Among other things, it explicitly guides states to allocate vaccines in part by race and ethnicity, something that the National Academy specifically avoided.  (Playbook, cited above, page 15).

And now, what do we see?  No fewer than five Federal agencies have notified their essential employees that they are going to get the vaccine first.  Oddly, I don’t see Federal employees listed by the National Academy of Medicine as a separate category.  In fact, if you read the Playbook document, it clearly says that Federal agencies will get a direct allocation only after there is adequate supply for all other critical populations.  But, presumably, they’ve just quietly arranged to have that happen.

And I just have this feeling that that’s how this whole process is going to work. Is this going to be a friends-and-family distribution plan?  Essential Federal employees are first line because they have an in.  And you don’t.  It’s as simple as that.

Can we at least put a finger on who, exactly, is making that allocation decision?  Who is going to determine how many doses go to which states?  Hah.  Here’s the sum total of information provided about how that will be done.

"The federal government will determine the amount of COVID-19 vaccine designated for each jurisdiction"

Playbook, cited above, page 29.

The CDC playbook is incredibly prescriptive about just how the States should allocate their supplies, within each State.  But exactly how the Federal government is going to allocate the supplies across States is more-or-less a complete black box.  Who will make that allocation decision, and by what rules, if any, are complete unknowns.

I have read that document pretty much start-to-finish, and that line you see in the box above, that is the sum total of information on how the vaccines will be distributed across the states.  Plus the vague reference to populations and disease spread.  More or less, allocation will be determined by the federal government.  Full stop.

At this point, it’s not even clear to me that they will, in fact, disclose the allocation.  This is a situation that is begging to be abused.  In an administration that prides itself on ignoring normal boundaries of good civil government.

It’s not as if the ordinary citizen has any say in this.  But it’s well worth keeping an eye on.  This allocation decision — how many doses go to which states — could have a profound effect on the near-term course of the pandemic.  Something that’s this important should not be done in the dark. 

But as far as I can tell, this is our vaccine allocation plan, in its entirety:  “The federal government will determine the amount of COVID-19 vaccine designated for each jurisdiction”.

Addendum:  If you want to read Virginia’s plan, it’s here (.pdf), courtesy of the KFF website cited above.  Among other things, you can see the criteria Virginia will use to allocate across jurisdictions, and some crude maps showing location of pharmacies that already have vaccine agreements in place with the Commonwealth.