In reviewing the CDC "proposal" for management and implementation of the vaccination program they note:
An adequate network of trained, technically competent COVID-19 vaccination providers in accessible settings is critical to COVID-19 Vaccination Program success. For this reason, COVID-19 vaccination provider recruitment and enrollment may be the most critical activity conducted before vaccine becomes available. Jurisdictions and tribal organizations should concentrate early planning efforts on engaging those vaccination providers and services that can rapidly vaccinate initial populations of focus as soon as a COVID-19 vaccine is available (Phase 1). Subsequent planning should include measures for recruiting and enrolling enough providers to vaccinate additional critical populations and eventually the general population when sufficient vaccine supply is available (Phases 2 and 3). Vaccination Provider Recruitment Jurisdictions are encouraged to immediately reach out to potential COVID-19 vaccination providers and target the appropriate settings so that COVID-19 vaccination services are accessible to the initial populations of focus when the first COVID-19 vaccine doses arrive. Providers and settings that maximize the number of people who can be vaccinated should be prioritized for enrollment; however, jurisdictions should ensure social distancing and other infection control procedures can be maintained in selected settings (see CDC guidance on vaccination during a pandemic).
All providers/settings, especially those enrolled for Phase 1, must able to meet the reporting requirements discussed in Section 9: COVID-19 Vaccine Administration Documentation and Reporting and Section 11: COVID-19 Requirements for Immunization Information Systems or Other External Systems. Jurisdictions should consider partnering with the private sector and with local hospitals or health systems to provide COVID-19 vaccination in the closest proximity possible to the initial populations of focus. For example, partnering with critical access hospitals will be key to vaccinating Phase 1 populations in rural areas. Suggested early COVID-19 vaccination providers/settings include:
• Large hospitals and health systems
• Commercial partners (e.g., pharmacies)
• Mobile vaccination providers
• Occupational health settings for large employers
• Critical access hospitals, RHCs, community health centers, or other central locations that can provide vaccination services for a broad area
CDC is working to engage large pharmacy partners to assist with on-site vaccination in LTCFs. These partners have existing distribution and administration infrastructure (including cold chain) and relationships with some LTCFs to provide medication and, in some cases, vaccination services (e.g., seasonal influenza) for staff and residents in LTCFs; this may reduce burden on jurisdictional health departments.
CDC will ensure jurisdictions have visibility on this work with large pharmacy partners. Jurisdictions should recruit additional COVID-19 vaccination providers to expand equitable access to COVID-19 vaccination when vaccine supply increases. Enrollment activities should be tracked so vaccination providers are not approached multiple times.
Unfortunately this is a general statement lacking specificity. The last sentence is the most critical. It leaves the details to the jurisdictions, I assume States. Unfortunately we saw how well this worked. But fundamentally the CDC is ill equipped to manage this effort. As they say, the devil is in the details.
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