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HealthyWomen Joins Nationwide Well being Organizations in Letter to HHS Secretary Alex Azar About Entry to COVID-19 Remedy

November 11, 2020

The Honorable Alex Azar

U.S. Department of Health

200 Independence Avenue, SW

Washington, DC 20201

Dear Secretary Azar:

The COVID-19 pandemic has exposed deep and systemic inequalities in our healthcare system. Members of minorities and underserved communities not only suffer more often from the serious health consequences of SARS-CoV-2 infections, but also disproportionately from economic difficulties in connection with the pandemic. Our organizations are committed to advancing policy solutions to address these differences head-on in the hope of not only mitigating the effects of the current pandemic, but also promoting a fairer and more equitable health system going forward.

We agree that we call for an informed, thoughtful, equity-based resource allocation and distribution during the current pandemic. This environment has raised difficult questions about how scarce resources are allocated. Whether determining where to ship physical products (vaccines, drugs, reagents, PPE, etc.) or COVID-19 funds, policymakers at all levels must consider equality and health inequalities when prioritizing where these resources will be sent.

Early evidence on distributions from the Provider Relief Fund (set by the CARES Act) suggests that the proportion of privately insured patients predicts a financial health system better than the proportion of patients from minority communities. Conversely, researchers in Michigan developed a framework that initially assigns scarce remdesivir doses based on criteria that explicitly recognize the areas of disproportionate disease burden: first doses should go to communities with the highest mortality rate and the highest rolling number of fans. This prioritization, along with in-depth confidence-building efforts, can help address the underlying trust issues in historically underserved or abused communities.

These and other examples from the past seven months have shown that the methods underlying the allocation strategies are by no means neutral with regard to health equality – they are powerful drivers that have the potential to correct or correct health differences in the allocation of scarce resources to tighten. Given the varying effects of COVID-19 on minorities and underserved communities
we strongly believe that allocating resources without recognizing these realities can exacerbate barriers to access to COVID-19 treatments.

We anticipate that the importance of allocation strategies that prioritize equity will only increase if novel therapies to treat COVID-19 are hopefully approved in the coming months. The United States government is likely to play a key role in distributing the initial supply of these therapies across the country.

While your office prepares to sell these products, we offer the following recommendations:

  • In the context of the COVID 19 pandemic, explicitly set the promotion of health equality as the goal of the allocation decisions of ASPR.
  • In consultation with relevant stakeholders and experts, establish evidence-based criteria that will guide the product into areas where there is a disproportionate burden of disease or other resource constraints (if applicable).

  • Communicate these decisions and criteria openly with the public.

  • Develop and communicate the process by which these criteria could be changed as the burden of disease shifts to other populations or communities.

We note that the National Academies of Medicine have set guiding principles for their reflection in their report on the Framework for the Fair Allocation of COVID-19 Vaccines. These guiding principles also align with our recommendations, and we believe they could be helpful in developing similar strategies for the distribution of COVID-19 therapeutics.

We believe such efforts are necessary to ensure that ASPR allocation decisions do not ignore the realities of health inequalities in this country or inadvertently widen them by choosing inappropriate metrics.

Our organizations stand ready to work with you in this effort and welcome further discussions on how your allocation strategies can better promote health equity.

Sincerely yours,

Alliance for Age Research

American Cancer Society, Cancer Action Network

Association of Black Cardiologists

Biotechnology innovation organization

The health of black women is essential

Genetic Alliance

Gerontological Society of America

Grapevine health

Healthcare ready

Healthy women

Hill Scientific and Public Affairs, LLC

Institute for Advanced Clinical Studies

Latinos for Equity in Healthcare

Lupus Foundation of America

National Black Church Initiative

National Caucus and Center for Black Aging

National Health Council

National Hispanic Council on Aging

National Forum for Minority Quality

National AIDS Council for Minorities

Coalition for Preparedness and Treatment

PXE International

Sick cells

The Commonwealth Fund

The National Grange

Trust for America’s Health

US Black Chambers, Inc.

cc: Dr. Robert Kadlec, Assistant Secretary for Preparedness and Response, HHS Cicely Waters, Director, Foreign Affairs Bureau, ASPR, HHS

Laurie Zephyrin et. al., “COVID-19 more common, more deadly in US counties with higher black populations,” To the Point (blog), Commonwealth Fund, April 23, 2020

Yaphet Getachew et. al., “Beyond the Case Count: The Far-Reaching Differences of COVID-19 in the United States,” Commonwealth Fund, September 10, 2020

Shanoor Seervai, “Why Are More Black Americans Die Of COVID-19?”, June 26, 2020, in The Dose, Produced by Joshua Tallman and Shanoor Seervai, Podcast, MP3 Audio, 10:29 PM. https://doi.org/10.26099/9phb-x473

Parker Crutchfield et al. al., “Ethical Allocation of Remdesivir,” The American Journal of Bioethics, July 27, 2020

National Academies of Science, Engineering and Medicine. 2020. Framework for equitable distribution of the COVID-19 vaccine. Washington, DC: The National Academies Press. https://doi.org/10.17226/25917.

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