January 11, 2021
To help expedite the administration and distribution of COVID-19 vaccines, the California Department of Public Health (CDPH) has issued additional guidance clarifying the rules for vaccine administrators, including physicians.
In its new guidelines, CDPH made clear that recipients in Phase 1a – health care workers and residents and staff of long-term care facilities – should still receive top priority for vaccinations. But the department stipulated that “after focused and appropriate efforts to reach the individual groups currently prioritized, health departments and providers may offer doses promptly to people in lower priority groups when demand subsides in the current groups, or doses are about to expire according to labeling instructions.”
The revision comes after concerns raised by physicians and other vaccine administrators about potentially punitive measures taken against those who are administering COVID-19 vaccination to patients. While CMA and other health care stakeholders support the equitable distribution of the COVID-19 vaccine, we also believe that strict adherence to the phases and tiers can create potential problems and slow the overall administration of the vaccine.
In states like New York, there have been stories of vaccine going to waste in part because health care workers were afraid of potential sanction. New York, like California, has since modified its guidelines to ensure that given the choice between vaccinating patients out of order and being faced with potential vaccine waste, it would be better to use the vaccine, even if that means giving a dose to a patient who may be in a subsequent tier.
California, like other states, is still in the middle of vaccinating health care workers under Phase 1a. Under current guidelines, essential workers as defined by the state will be vaccinated under Phase 1b, which is expected to being in the coming weeks.
Given the limited supply of COVID-19 vaccines, CDPH recommends balancing the prioritization of these scarce resources to maximize the goal of achieving community immunity for all Californians.
After focused and appropriate efforts to reach the individual groups currently prioritized, health departments and providers may offer doses promptly to people in lower priority groups when:
- Demand subsides in the current groups, or
- Doses are about to expire according to labeling instructions.
To maximize vaccine administration and reduce the potential for vaccine wastage, local health departments and providers should immediately administer COVID-19 vaccines to individuals in all tiers of Phase 1a. Providers offering vaccines should consider partnering with other providers or organizations to provide vaccinations for individuals in the prioritized tiers. However, local health departments and providers should make special efforts to administer the vaccine to vaccinators.
Local health departments and providers may allocate doses on the assumption that immunization will be accepted by some but not all who are offered the vaccine, and then continue to offer vaccinations to all individuals in progressive priority tiers. If a county has maximized use of the vaccine to administer individuals in Phase 1a, they should move to Phase 1b, Tier 1 while continuing to offer vaccines to those in higher priority groups.