"Although IDSA applauds HHS's efforts on a thoughtful and scientifically based plan, we are proposing a number of recommendations that, if incorporated, could help to strengthen the
Among other things, IDSA is calling for a regular, perhaps annual, timetable for updating the plan so that it can remain current and evolve with science and policy. "IDSA believes it's important for the plan to emphasize international collaboration and outline a role for the
IDSA offered HHS recommendations in the following areas:
-- Coordination and stakeholder buy-in: IDSA calls for a pre-established strategy to facilitate rapid communication between HHS and other federal agencies, state and local public health officials, medical societies, physicians, and other health professionals. Specifically, IDSA recommends that the National Vaccine Program Office (NVPO) should have ultimate responsibility for coordinating efforts within HHS and with other federal agencies. As such, NVPO would oversee domestic and international influenza activities, including surveillance and supply of vaccines and antivirals.
-- Coordination and accountability of the research agenda: IDSA recommends forming an advisory committee to coordinate the various influenza research efforts being undertaken by government agencies, independent researchers, and industry. A progress report should be compiled and published on a regular basis.
-- Consistency of recommendations and implementation: Given the confusion that has resulted during this year's flu shot shortage, IDSA calls for clear, national guidelines to identify--in advance of a pandemic--priority groups for vaccine and antiviral use, as well as containment methods and strategies to decrease the transmission of disease.
-- Interpandemic influenza: There is much to be learned about how best to respond to a pandemic influenza outbreak, during the annual influenza season. IDSA urges the federal government to use this time and the lessons learned during these annual outbreaks wisely. Specifically, IDSA recommends strengthening vaccine and antiviral distribution networks; investing in research to advance what we know about influenza and how best to respond; developing prevention, control and treatment strategies; identifying resource needs; and building infrastructure and capacity.
-- Vaccine supply: Because the influenza virus changes from year to year, a reliable stockpile of flu vaccine cannot be built beforehand. However, IDSA recommends that small seed stocks of candidate vaccine strains be developed and tested. Because the pneumococcal vaccine can prevent certain complications of influenza, the Society recommends that HHS consider stockpiling this vaccine. IDSA also urges the development of specific and realistic plans to rapidly create a vaccine in sufficient quantity, as well as a system to track the distribution of vaccine and antivirals.
-- Antiviral supply: IDSA recommends stockpiling antiviral drugs that can be used to treat influenza and stop the spread of infection. A specific strategy should be developed to distribute antiviral drugs to states, local health departments, and other points of care.
Legislation to spur development of vaccines and antivirals: IDSA advocates legislation to spur the research, development, and licensing of new vaccines and antivirals. Specific strategies worth exploring include market incentives, risk reduction, liability protections, compensation for injury, intellectual property rights, tax credits for research, and a guaranteed federal purchase plan.
-- Funding: IDSA believes that the Administration's request of $100 million for pandemic influenza activities in fiscal years 2004-2005 seriously underestimates the amount of funds realistically needed to effectively respond to the next pandemic.
"An investment in infrastructure and capacity to effectively respond to influenza will yield benefits every year, whether or not a pandemic occurs," said Pavia. In addition, IDSA believes that, in the event of a flu pandemic or other serious infectious disease outbreak, the Executive Branch should be able to trigger an emergency funding mechanism so that federal officials may respond quickly.
IDSA's comments were submitted in an Oct. 26, 2004 letter to HHS. The comments are available on the IDSA's Web site at www.idsociety.org.