Minister for Health and Social Services
COVID Vaccination Governance
18 January 2020
Director of Public Health Policy
- Background
Ministers current policy for vaccination prioritisation is based on the work of the UK’s Joint Committee for Vaccination and Immunisation (JCVI). JCVI’s work has been thorough and evidence based and has provided a strong rationale for prioritisation based on ‘prevention of mortality and the maintenance of health and social care systems’.
The work of JCVI currently (updated 30 December 2020) comprises ‘Phase 1’ of the UK’s vaccination programme, and has established the following order of priorities:
- residents in a care home for older adults and their carers
- all those 80 years of age and over and frontline health and social care workers
- all those 75 years of age and over
- all those 70 years of age and over and clinically extremely vulnerable individuals
- all those 65 years of age and over
- all individuals aged 16 years to 64 years with underlying health conditions which put them at higher risk of serious disease and mortality
- all those 60 years of age and over
- all those 55 years of age and over
- all those 50 years of age and over
The Government of Jersey COVID vaccination programme is using the JCVI guidance as strictly as possible in determining the scheduling of vaccinations. JCVI have yet to provide guidance for Phase 2 (people aged under 50 years), which will deal with how the more general population should be prioritised.
- Issues and risks
Notwithstanding guidance from JCVI, Ministers will note that a range of questions and representations are being made to medics and other officers. These include:
- Questions of clarification (e.g. in the definition of ‘health and social care workers’)
- Representations that seek to advance prioritisation (e.g. teachers, vulnerable children)
- Representations for the use of ‘spare’ vaccine (currently small amounts left over at the end of a day where appointments have not been fulfilled)
Currently, representations are considered by the Deputy Medical Officer for Health in consultation with the Head of Vaccination Programme. It is likely such representations will increase in scale and variety over time once the very high-risk groups are vaccinated and eligibility approaches for larger sections of the population.
Further, there is a risk of legal challenge should individuals or organisations believe their queries, complaints, or representations have not been considered adequately.
- Recommendation
It is therefore recommended that the Minister for Health and Social Services authorise the rapid establishment of a clinically led COVID Vaccination Panel (the “Panel”) to mitigate the issues and risks set out above and provide for clinical governance.
Draft Terms of Reference for the Panel are set out in Appendix 1. These have been considered by STAC who are supportive.
Appendix 1: COVID Vaccination Panel
Terms of Reference
Purpose / aim of the Panel
- To determine whether persons will be offered COVID-19 vaccinations in advance of standard eligibility (the term ‘standard eligibility’ refers to the point at which those persons would be offered the vaccine in accordance with JCVI prioritisation).
Where the Panel anticipates that a determination of advance vaccination may impact delivery of the vaccination programme, the Panel must consult the Minister for Health and Social Services before making that determination (for example: where multiple persons have shared circumstances).
- In making their determination the Panel will consider the following factors:
- JCVI guidance / any strategic implications of divergence from JCVI guidance
- supply of vaccines and sufficiency of supply to vaccinate in accordance with JVCI priorities
- local data relating to clusters / environments or activities susceptible to transmission
- risk of becoming infected due to environment in which persons live or work (and supporting data)
- risks of serious illness / death infection based on persons’ exposure to Covid (and supporting data)
- other mitigating circumstances that the Panel consider relevant (including medical, social or environmental factors)
- emerging evidence around efficacy of the vaccine
- previous precedents that arise from Panel decision making
- The aim of the Panel is to make fair, reasonable and transparent decisions which balance a person/s needs and circumstances against the need to ensure adherence to JCVI prioritisation and without potential disadvantage to other or inequity of treatment.
- For the avoidance of doubt a person / groups of persons will not be offered advanced vaccination if the provision of advance vaccination delays vaccination of others in accordance with JVCI prioritisation (i.e. advance vaccination will only be offered if both supplies of vaccine and the operational capacity to vaccinate are sufficient to avoid delayed vaccination of persons who fall within JVCI priority groups)
Submissions
- Panel will only consider and determine written submissions. In determining those submission the Panel may seek / require additional information, data or evidence.
- The Panel will seek to respond to all submissions within 2 weeks of receipt subject to the need to seek additional information, data or evidence.
- Written submissions will only be received from:
- registered medical practitioners / Jersey registered healthcare professionals
- established entities for example trade unions, industry representatives, professional bodies, registered charities, regulators, consuls
- States members
- Written submissions will not be accepted directly from members of the public.
- There will be no appeals to the Panel’s determination.
Membership and procedures
- The Panel will consist of a Chair and between 5 to 7 other members.
- The Panel Chair and members will be appointed by the Minister for Health and Social Services via Ministerial Decision
- The Chair must be a medical practitioner with experience of medical ethics
- Other panel members will include:
- Associate Medical Director, primary care governance
- Chief Pharmacist
- Patient and / or community representative/s
- Medical Officer for Health / Deputy Medical Officer for Health
- The Panel will determine its own procedures and meeting schedule subject to matters sets out below:
- minimum of 3 members must be present for the Panel to be quorate. This must include the Chair, or a person nominated by the other Panel members to act as Chair for the purpose of that meeting. The nominated Chair must be a medical practitioner.
- the Panel may meet on-line but all decisions must be recorded in writing.
- The lead advisor to the Panel will be the Head of GoJ vaccination programme.
A secretariat will be provided by HSC to the Panel