Vaccine Allocation Letter to the CDC Advisory Committee on Immunization Practices (ACIP)

January 22, 2021

CDC Advisory Committee on Immunization Practices

[Docket No. CDC–2021–0002] Federal Register

RE: Individuals with Alpha-1 Antitrypsin Deficiency (the leading genetic risk factor for developing COPD) need priority access to COVID-19 vaccine

Dear Advisory Committee Members:

The Alpha-1 Foundation recommends that the Advisory Committees favorably consider individuals with Alpha-1 Antitrypsin Deficiency amongst those individuals with underlying conditions who urgently need to gain priority access to COVID-19 vaccines.  The timely meeting of the Advisory Committee under the auspices of a new Administration offers our rare disease community hope that the Federal government will exercise greater influence and authority over the allocation and distribution of vaccines within the states.

Allocation is of great interest to the Foundation as we support individuals who have the genetic condition Alpha-1 Antitrypsin Deficiency, or Alpha-1 for short.  Alpha-1 causes severe COPD (emphysema) and bronchiectasis in the lungs of adults with this condition, often appearing during an individual’s prime earning years.  In addition, Alpha-1 can cause liver disease in infants, children, and adults often leading to liver transplantation.  The majority of adults identified with Alpha-1 have significant lung impairment and have been demonstrated to have an increased risk of severe disease and death should they develop COVID-19 infection.  While many individuals with Alpha-1 have remained free of COVID-19 because of careful adherence to recommended preventive measures, those who do become infected are more likely to spend time in the hospital and intensive care.  A significant number of those with Alpha-1 and COVID-19 have died.

In September of 2020 the Foundation reached out to the National Academies of Science, Committee on Equitable Allocation of Vaccine for the Novel Coronavirus after the release of the Discussion Draft of the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine. We encouraged expansion of the definition of Chronic Obstructive Pulmonary Disease (COPD) to include Alpha-1 Antitrypsin Deficiency.

As an organization that represents individuals with genetic COPD we are particularly interested in the mitigation of negative effects on those with pre-existing conditions. This rare disease population is amongst the most vulnerable for severe outcomes because of the comorbid condition of lung tissue loss and decreased immunity.  Many risk factors for severe COVID-19 disease have been identified including advanced age, obesity, diabetes, and hypertension which are often comorbidities in the Alpha-1 patient population.

It is our greatest hope that the ACIP recommend that Alpha-1 Antitrypsin Deficiency be included in the definition of COPD and be prioritized for COVID-19 vaccination.



Miriam O’Day                                                   Robert A. Sandhaus
President & CEO                                              Clinical Director
Alpha-1 Foundation                                         Alpha-1 Foundation