DEPARTMENT OF HEALTH AND HUMAN SERVICES
Office of the Secretary
Assistant Secretary for Health
Office of Public Health and Science
Washington D.C. 20201
MAR 13 2009
Claire Broome, M.D., M.P.H.
IOM Committee Chair
Institute of Medicine
500 5th Street NW Washington DC 20001
Re: Incorporation of recommendations to National Vaccine Plan to ensure coordination of vaccination activities within the Federal government and with non-governmental partners
Dear Dr. Broome:
The National Vaccine Advisory Committee (NVAC), an advisory group to the U.S. Department of Health and Human Services (HHS) authorized by Section 2105 of Title XXI of the Public Health Service Act, would like to offer comment on the update to the National Vaccine Plan.
As stated in Section 2105(4) of Title XXI of the Public Health Service Act (P.L. 99-660), the NVAC shall “advise the Director of the [National Vaccine] Program in the implementation of sections 2102 and 2103 of the Act, which include coordinating governmental and non-governmental activities. As part of this charge, NVAC recently adopted its 2008 State of the Program Report which includes a series of recommendations. A copy of the Report is attached A central concern of NVAC in the current conduct of the National Vaccine Program (NVP) is the need for better coordination by NVPO, particularly of federal agency vaccine efforts, and sufficient resources to carry this out. The NVAC’s four recommendations in the Report are:
The NVP should be given the resources and effective organizational authority within HHS necessary to carry out its mission to coordinate and direct the vaccine-related efforts of the federal PHS agencies. Having the NVP report directly to the Secretary of HHS would achieve the needed organizational authority.
The National Vaccine Plan should specifically address how the NVP will improve its effectiveness.
The NVP should be evaluated regularly and its effectiveness reviewed as part of each revision of the National Vaccine Plan.
The NVPO should improve the effectiveness of the NVAC based on the recommendations of the pending NVAC evaluation report.
U.S. Public Health Service
The NVAC feels that the draft National Vaccine Plan does not go far enough to address coordination of vaccine-related activities both at the Federal level and with non-governmental partners. This role was highlighted in the 1994 National Vaccine Plan, and again in the June 2008 Initial Guidance for an Update of the National Vaccine Plan: A Letter Report to the National Vaccine Program Office, which stated:
[T]he principal coordinating organization for the [National Vaccine Program] NVP is the National Vaccine Program Office (NVPO), within the Public Health Service (PHS). The NVPO’s responsibilities include providing overall leadership for the collaborative effort and monitoring the progress being made in achieving the plan’s goals. Within the PHS, the NVPO has the task of reviewing all budget requests associated with vaccine development and immunization programs to ensure that all major priorities are adequately covered and that there is no duplication of effort.
The NVAC urges the Institute of Medicine recommend as part of its critique of the draft National Vaccine Plan that the final Plan adequately and appropriately addresses the ability of the National Vaccine Program to coordinate between the many varied partners and stakeholders involved in immunization in the United States, and that it be given an adequate administrative structure and resources to do so.
Please don’t hesitate to contact me if I can provide more information on behalf of the Committee. I can be reached through the National Vaccine Program Office, HHS at 202-690-5566.
Guthrie S. Birkhead, M.D., M.P.H.,
National Vaccine Advisory Committee