Public comment to CDC's vaccination recommendation committee ACIP
Due today 6/16/2023
Please join me in supporting access to boosters at least every 6 months. You can find additional resources and instructions on how to submit public comment on the People’s CDC substack.
My comment is below.
This is an update to the comments I submitted to the CDC in February 2023 and in April 2023, and to the FDA VRBPAC in June 2023. As a physician-scientist, I support increasing the frequency of COVID boosters to at least every 6 months broadly, not just for selected groups such as the elderly or immunocompromised. This fall’s updated vaccine formulations should also be made available for all age groups, including children aged 6 months and older.
Currently, as a non-immunocompromised adult under the age of 65, I am only eligible for boosters on an annual basis. My last booster was in fall 2022, and I will receive the updated booster in fall 2023 as soon as I can. Everyone must have the option to better protect themselves, especially given the premature loss of many pandemic public health resources and protections with the end of the federal public health emergency.
The preponderance of all available evidence supports the fact that immunity wanes in the months following vaccination, and recommending boosters (all authorized vaccine types) at least every 6 months permits all of us who are at risk to maintain better protection than with only annual boosters. Particularly, I urge you to recommend boosting with mRNA vaccines at least every 6 months, given the higher proven effectiveness of these vaccines (one recent comparative example [1]).
All of us are vulnerable to COVID infection, and recommending boosters every 6 months will reduce barriers to high levels of protection for all of us, including individuals who are frequently exposed due to the lack of COVID mitigations in our schools and workplaces, the millions of Americans who already have long COVID and are at risk of additional damage and disability due to reinfection, as well as traditional risk groups such as those who are immunocompromised, those at high risk of severe disease [2], and the elderly. Vaccination is known to reduce the risk of long COVID [3]; however, the impact of waning immunity on this effect has not been sufficiently studied. Given the ongoing public health crisis of long COVID, including among people who are young and were previously healthy, we must follow a precautionary approach and err on the side of recommending more frequent boosting.
Given the excellent benefits and exceedingly low risks of vaccination, as well as the significant societal risks of living through an ongoing airborne pandemic with repeated COVID exposure in daily life, it is a mistake to deny boosters at least every 6 months to the broader population.
I am a member of the People’s CDC, and you can find more information and references supporting a 6-month booster frequency on the People’s CDC substack post [4].
References
1. Liu B, Stepien S, Qian J, Gidding H, Nicolopoulos K, Amin J, Cheng A, Macartney K. Comparative Effectiveness of Four COVID-19 Vaccines, BNT162b2 MRNA, MRNA-1273, ChAdOx1 NCov-19 and NVX-CoV2373 against SARS-CoV-2 B.1.1.529 (Omicron) Infection. Epidemiology; 2022. doi:10.1101/2022.12.22.22283869 URL: https://www.medrxiv.org/content/10.1101/2022.12.22.22283869v2
2. https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-medical-conditions.html
3. Thaweethai T, Jolley SE, Karlson EW, et al. Development of a Definition of Postacute Sequelae of SARS-CoV-2 Infection. JAMA. Published online May 25, 2023. doi:10.1001/jama.2023.8823
4.