The Massachusetts Medical Society appreciates this opportunity to provide comment regarding the proposed amendments to standardize COVID- 19 and influenza vaccination requirements across all licensed health care facility settings, and Emergency Medical
Service (EMS) providers. The MMS is a professional association of over 25,000 physicians, residents, and medical students across all clinical disciplines, organizations, and practice settings. The Medical Society is committed to advocating on behalf
of patients, to provide timely access to high quality, safe health care, and on behalf of physicians, to help them provide the best care possible. We have long supported policy measures that strengthen public health and believe vaccines are a critical
public health tool that provide a safe and effective means to protect society from infectious and potentially deadly diseases.
The COVID-19 pandemic has necessitated review and updating of public health policies related to vaccines, which has highlighted the issue of vaccine hesitancy and skepticism. We believe that unvaccinated health care workers place themselves and their
patients at increased risk of illness. In the context of a highly transmissible disease that poses significant medical risk for underserved and/or vulnerable patients or colleagues, or threatens the availability of the health care workforce – particularly
a disease that has potential to become epidemic or pandemic, and for which there is an available, safe, and effective vaccine – physicians and health care workers who have direct patient care responsibilities have an ethical obligation to accept immunization
unless there is a documented medical contraindication. In scenarios in which there is a documented medical contraindication to immunization, consistent with the intent of these proposed changes, physicians and health care workers should take appropriate
protective measures.
Despite our view that physicians and health care workers have an ethical obligation to be vaccinated, and while the MMS supports efforts by the Massachusetts Department of Public Health (DPH) and other health care organizations and institutions to maximize
immunization rates for all direct patient contact health care personnel, we encourage – consistent with our long-standing policy – a voluntary framework for vaccination. However, if a voluntary program for vaccination proves unsuccessful at maximizing
immunization rates, then the MMS would support regulations imposing a mandatory immunization program for the COVID-19 vaccine.
Within the context of a mandatory immunization program, the Medical Society opposes nonmedical vaccine exemptions for all settings in which vaccines are required in Massachusetts. As such, should the Department move forward with standardizing COVID- 19
and influenza vaccination requirements across all licensed health care facility settings, the Medical Society believes the only appropriate exemption should be a medical exemption. Otherwise, a mandate that allows health care workers to opt-out for
any reason is not a true mandate and cannot realize the full efficacy of such a policy. Substantial evidence shows that vaccination mandates (before the COVID-19 epidemic) have been effective, with states that have eliminated personal-belief or religious
exemptions (while maintaining medical exemptions) for school-entry vaccine requirements have lower exemption rates and higher vaccination rates. While less evidence is available concerning adults, there are increasing reports that COVID-19 vaccination
mandates for health-care workers, emergency first responders, federal workers, school staff, university students and staff, and other groups have garnered high levels of compliance. While we appreciate and understand the legitimate concerns regarding
the potential impact of a COVID-19 vaccine mandate on the workforce given the significant shortages and current challenges, we must prioritize the health and safety of our patients and our health care providers.
Lastly, we agree with the requirement that staff in long-term care and hospice facilities who decline vaccination or otherwise qualify for an exemption must take mitigation measures to prevent viral infection and transmission. We would strongly encourage
that this policy be applied consistently across all facilities such that anyone who is exempt from receiving a COVID-19 vaccination is required to take mitigation measures. The regulations as currently proposed are permissive, allowing employers to
require individuals who decline vaccination to take mitigation measures – we believe this should be mandatory. Lastly, we believe it prudent and encourage the Department to outline in the regulations that wearing a mask is a required mitigation strategy.
Moreover, we encourage the Department to further articulate examples of evidence-based mitigation strategies, which we recognize may evolve.
The Massachusetts Medical Society is grateful to the Department of Public Health for taking steps to protect the health and safety of the Commonwealth by advocating for health care worker vaccination against flu and COVID-19. Thank you for your consideration
of these comments. For any questions, please contact Leda Anderson, Director of Advocacy & Government Relations, at landerson@mms.org.
View a PDF version of these comments here.
