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Dear Chairwoman McCarthy Vahey, Chairman Anwar, Ranking Members Klarides-Ditria and Somers and Members of the Committee:
On behalf of the Biotechnology Innovation Organization (BIO), I write to share comments and suggested language changes for Senate Bill 450, “An Act Concerning the Standard of Care for Immunization.” BIO applauds and thanks you, the Governor and the Department of Public Health for your commitment to ensuring access to vaccination for all residents in Connecticut. We offer the following comments for consideration to ensure product availability, access, and choice are not unintentionally limited for Connecticut residents because of this legislation.
BIO is the world’s largest trade association representing biotechnology companies, academic institutions, and industry affiliates across the United States and in over 30 countries. BIO membership includes vaccine developers and manufacturers who have worked closely with the public health community to support policies that help ensure access to innovation and lifesaving vaccines for all individuals.
BioCT is the life sciences trade organization for the state of Connecticut. The not-for-profit organization serves as the voice of more than 300 member companies. Its mission is to catalyze and accelerate growth in the life sciences with the goal of improving human health, by fostering a rich, innovative ecosystem, and promoting Connecticut as a preferred destination for life sciences exploration and innovation. To learn more, visit https://bioct.org.
Clarification on Definition of Vaccine
While vaccination and immunization have become synonymous in everyday language there are slight technical differences. BIO is concerned that only describing immunization as “active” on line 14 of the bill potentially omits products that are used in a vaccine-like manner to prevent and reduce severity of infectious diseases. For example, monoclonal antibodies (mAbs) provide protection to babies and infants against RSV and are included on both the Advisory Committee for Immunization Practices (ACIP) and American Academy of Pediatrics (AAP) immunization schedules. While not “active” immunization, RSV mAbs are a key tool in the overall immunization toolbox to fight a severe public health problem. To be inclusive of all current and any future innovations and products in the vaccine and immunization space and to ensure continued access to all approved products in Connecticut, BIO recommends updating the language in the bill to include both “active and passive” vaccination. Including reference to both passive and active immunization helps to ensure that statutory language keeps pace with evolving science and reflects ACIP’s and AAP’s current and future immunization schedules. We welcome the opportunity to work with the legislature in a constructive manner to amend this language.
Language to Support Individual and Provider Choice
Individual and provider choice in vaccines, when multiple are available in a given class, is fundamental to the US vaccination system to support freedoms of individuals and allow medical providers to recommend and supply their patients with the best vaccine options based on individual needs. Provider choice means providers decide what immunization is best for their patients and is a fundamental principle of the US vaccination system.
A recent survey of vaccine providers in New England found that over 70% consider vaccine choice important. Among pediatricians, that number rises to 74%. Providers know their patients best and must be empowered to select the vaccine that best meets individual needs, clinical circumstances, and public health goals. In order to ensure this access, BIO recommends adding language to the bill to ensure that provider choice continues in Connecticut.
This addition of provider choice language would strengthen SB 450 and Connecticut’s immunization strategy in several important ways.
We look forward to working with the legislature to develop specific language to ensure that provider choice is maintained in Connecticut in the state vaccine program.
As an industry, our expertise lies in scientific research, development, and manufacturing of medications and preventive measures. We strive to provide accurate and reliable information based on scientific evidence and expert guidance. BIO’s vaccine manufacturer members remain committed to continuously working with federal and state policy makers to ensure vaccination policies reflect the best available science and serve the needs of both providers and patients. As such, we respectfully ask the Committee to consider these comments and language additions in SB 450 so that product availability, access, and choice are not unintentionally limited for Connecticut residents. We welcome the opportunity to engage further in any discussion of this legislation.
Sincerely,
Stephen Burm
Director, State Government Affairs (Northeast)
Biotechnology Innovation Organization (BIO)
Jodie Gillon
President & CEO, BioCT