Physicians for Informed Consent Letter to the Department of Health and Human Services (HHS) on Developing the 2020 National Vaccine Plan

Tammy R. Beckham, Director
Office of Infectious Disease and HIV/AIDS Policy (OIDP), Office of the Assistant Secretary for Health, Office of the Secretary, Department of Health and Human Services (HHS)

October 24, 2019

RE: Request for Information (RFI) From Non-Federal Stakeholders: Developing the 2020 National Vaccine Plan

Dear Dr. Beckham,

We believe the top priority for the 2020 National Vaccine Plan should be to clearly quantify the risk of infectious diseases versus the risk of their respective vaccines, in order to enhance informed decision-making by consumers and health care providers. The reason this priority is important to us is because we have found critical calculation errors in government memorandums about infectious disease risk in the United States, including the Supplementary Information provided in the “Request for Information (RFI) From Non-Federal Stakeholders: Developing the 2020 National Vaccine Plan.”¹

For example, a calculation error which occurred in the House Committee on Energy & Commerce Memorandum² for the hearing on “Confronting a Growing Public Health Threat: Measles Outbreaks in the U.S” is that “One or two deaths occur among every 1,000 children who acquire measles.” The second paragraph in the Memorandum 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 computes 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 annually among about 4,000,000 measles cases, which results in a one in 10,000 (0.01%) chance of a child dying from measles, not one in 500 or one in 1,000. By comparison, over 23,000 infant deaths occur every year in the U.S. and thus the chance of a child dying in his or her first year of life is currently one in 170 (0.6%)¹² – this is 60 times the risk of a child dying from measles in 1962, a time period when almost every child had measles by age 15.⁴

The reason this calculation error 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.⁴ 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 10,⁴ and the risks of the measles, mumps, and rubella (MMR) vaccine,⁵ are enclosed. Please carefully review 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.”⁶ This latter contradicts the estimated $20,000 cost per measles case quoted in the “Request for Information (RFI) From Non-Federal Stakeholders: Developing the 2020 National Vaccine Plan.”¹ Dr. Langmuir became director of the epidemiology branch of the Communicable Disease Center in 1949 and held the position for over 20 years, during a time when about 4,000,000 cases of measles occurred each year.

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, immune globulin, and ribavirin are indicated and available.^4,7-9 Therefore, the vaccination of others is not necessary in order to protect immunocompromised persons from severe measles, or other infections,¹⁰ 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 and rational doubt will continue to be raised about the MMR vaccine until a safety study with the statistical power to detect permanent injury from the vaccine in 1 in 10,000 vaccinated subjects is produced.⁵ Additionally, in 2017, we reported in the British Medical Journal (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.¹¹ 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.

Infant mortality rate (IMR) is a recognized major indicator of the health of a population, not the number of measles cases nor the number of vaccination exemptions.¹² For example, West Virginia and Mississippi, which only allow state public health officers to approve medical exemptions to vaccination have about double the IMR of California. And Massachusetts and Washington have a lower IMR than California, even while allowing non-medical exemptions.¹³ This means that laws limiting vaccination exemptions are unlikely to improve public health – and may worsen it.

We urge you to thoroughly discuss the errors and facts we have highlighted with your epidemiologists and statisticians, so that the 2020 National Vaccine Plan does not contain misinformation or threaten public health.

We are here to assist you.

Sincerely,

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

References

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