Physicians for Informed Consent: Errors in Memorandum for the hearing on “Confronting a Growing Public Health Threat: Measles Outbreaks in the U.S.” on February 27, 2019

February 25, 2019

Chairman Frank Pallone, Jr.
Committee on Energy and Commerce

Oversight & Investigations Subcommittee Of the House Committee on Energy and Commerce

RE: Errors in Memorandum for the hearing on “Confronting a Growing Public Health Threat: Measles Outbreaks in the U.S.” on February 27, 2019

Dear Chairman Pallone and Subcommittee Members,

In the introductory background section of the Memorandum1 for the hearing on “Confronting a Growing Public Health Threat: Measles Outbreaks in the U.S.,” it is written that “One or two deaths occur among every 1,000 children who acquire measles.” This is a critical calculation error, which requires your urgent attention and correction.

The second paragraph in the background section contains evidence of the error. It explains that prior to the introduction of the measles vaccine in 1963, “there were an estimated 3 to 4 million people infected with measles in the United States, and as many as 500 related deaths each year,” which is correct. However, this translates to a number of deaths which, at most, is one in 6,000 (3,000,000 divided by 500). More precisely, between 1959 and 1962, about 400 measles deaths occurred out of about 4,000,000 measles cases, which calculates to one death among every 10,000 children (0.01%) who acquire measles, not one in 500 or one in 1,000 as written in the introduction.

The reason this mistake unfortunately commonly occurs is because the Centers for Disease Control and Prevention (CDC) publishes case-fatality rates based on the number of reported cases only. And, since it is estimated that nearly 90% of measles cases are benign and therefore not reported to the CDC, the widely publicized measles case-fatality rate is a 10-fold miscalculation. Such an error has grave public health consequences.

Information available on total measles pre-vaccine cases (both reported and unreported to the CDC) in comparison with today’s leading causes of death in children under age 10,2 and the risks of the measles, mumps, and rubella (MMR) vaccine,3 are enclosed. Please carefully read these documents, as well as Dr. Alexander Langmuir’s 1962 article “The Importance of Measles as a Public Health Problem” where he explained, “…in the United States measles is a disease whose importance is not to be measured by total days disability or number of deaths.”4 Dr. Langmuir became director of the epidemiology branch of the Communicable Disease Center in 1949 and held the position for over 20 years.

Another error in the Memorandum is in the prevention and response section where it is suggested that no treatments are available for measles. In rare situations, such as vitamin A deficiency or a compromised immune system, measles can be severe and even deadly, if left untreated. In those situations, high-dose vitamin A and immunoglobulin (passive immunization) are indicated to treat or prevent measles upon exposure, respectively.2 In addition, there is evidence that the antiviral ribavirin is beneficial in the treatment of measles, and this requires further research.5-7 Therefore, the vaccination of others is not necessary in order to protect immunocompromised persons from severe measles, or other infections,8 and coercing such action would be highly unethical and unscientific.

Finally, the Memorandum states that “CDC has determined that receiving the MMR vaccine is safer than getting any of the viruses,” however this has not been scientifically demonstrated. In 2017, we reported in The British Medical Journal (The BMJ) that every year an estimated 5,700 U.S. children (approximately 1 in 640) suffer febrile seizures from the first dose of the MMR vaccine—which is five times more than the number of febrile seizures expected from measles.9 This amounts to 57,000 febrile seizures over the past 10 years due to the MMR vaccine alone. As 5% of children with a history of febrile seizures progress to epilepsy, a debilitating and life-threatening chronic condition, the estimated number of children whose epilepsy is due to the MMR vaccine in the past 10 years is 2,850. In addition, we contend that the Vaccine Adverse Event Reporting System (VAERS), as a passive surveillance system, does not adequately capture vaccine side effects and that serious side effects, including permanent neurological harm and death from the MMR and other vaccines, may similarly be underreported.

The National Childhood Vaccine Injury Act (NCVIA) of 1986 was created by Congress as a remedy to protect vaccine manufacturers from mounting vaccine injury lawsuits. Since then, the Vaccine Injury Compensation Program (VICP) it created has cumulatively awarded about $4 billion for severe vaccine injury cases or deaths—to only a small fraction of the VICP petitioners who apply within the three-year or two-year statute of limitations, respectively. Consequently, it is mostly families whose children have suffered vaccine injuries and the doctors who care for them who have a heightened awareness of the risks vaccines pose to some American children, in an environment that is effectively immune from the tort system, civil litigation, and publicity.

We realize the errors discussed above are technical, but we urge you to take the time to discuss them thoroughly with your epidemiologists and statisticians, as ultimately the Memorandum should be retracted. We also appreciate what pressure you must be under to protect public health, and hope you do whatever it takes to guarantee that the decisions you make are based on accurate information. The right to bodily integrity, and the health, of millions of Americans is at stake.

We are here to assist you.


Shira Miller, M.D.
Founder and President
Physicians for Informed Consent


  1. Memorandum Re: Hearing on “Confronting a Growing Public Health Threat: Measles Outbreaks in the U.S., Feb. 22, 2019.
    ( accessed Feb. 24, 2019)
  2. Physicians for Informed Consent. Measles – Disease Information Statement (DIS). Sept 2018. ( accessed Feb. 24, 2019)
  3. Physicians for Informed Consent. Measles – Vaccine Risk Statement (VRS). Dec 2017.
    ( accessed Feb. 24, 2019)
  4. Langmuir AD, Henderson DA, Serfling RE, Sherman IL. The importance of measles as a health problem. Am J Public Health Nations Health. 1962 Feb;52(2) Suppl:1-4.
    ( accessed Feb. 24, 2019)
  5. Roy Moulik N, Kumar A, Jain A, and Jain P. Measles outbreak in a pediatric oncology unit and the role of ribavirin in prevention of complications and containment of the outbreak. Pediatr Blood Cancer. 2013; 60: E122-E124.
    ( accessed Feb. 24, 2019)
  6. Pal G. Effects of ribavirin on measles. J. Indian Med Assoc. 2011.
    ( accessed Feb. 24, 2019)
  7. Uylangco CV, Beroy GJ, Santiago LT, Mercoleza VD, Mendoza SL. A double-blind, placebo-controlled evaluation of ribavirin in the treatment of acute measles. Clin Ther. 1981;3(5):389-96.( accessed Feb. 24, 2019)
  8. Physicians for Informed Consent. Vaccines: What About Immunocompromised Schoolchildren? July 2018. ( accessed Feb. 24, 2019)
  9. Miller S. BMJ 359 (2017):j5104, Re: The unofficial vaccine educators: are CDC funded non-profits sufficiently independent?
    ( accessed Feb. 24, 2019)

Enclosed: Measles Disease Information Statement, Measles Vaccine Risk Statement, Immunocompromised Schoolchildren Risk Group Information Statement, and “The importance of measles as a health problem” (PDF)