COVID-19 Vaccine Prioritization

February 12, 2021

Governor Charles Baker
Speaker of the House Ronald Mariano
Senate President Karen Spilka
Attorney General Maura Healy
Secretary Marylou Sudders
DPH Commissioner Monica Bharel
Members of the Advisory Committee

Re: COVID-19 Vaccine Prioritization for People with Intellectual and Developmental Disabilities and Autism

Dear Governor Baker and Other Distinguished State officials:

Thank you to the Administration, and the members of the Vaccine Advisory Group, for their work in developing and implementing the Commonwealth’s vaccine allocation and distribution plan.  The Arc of Massachusetts (The Arc), along with Advocates for Autism of Massachusetts and our constituents, appreciate the prioritization of congregate care settings, and providers of home and community-based services as well as the recent prioritization of some unpaid/family home care providers to receive the COVID-19 vaccine in Phase 1. We also thank you for considering our recent request to prioritize the vaccine for all people with intellectual and developmental disabilities (I/DD), including autism, enrolled in day and employment programs as well as to expand the category of home-cased health care workers to include unpaid family caregivers of people with I/DD.  As we noted previously, targeting these groups for vaccination prioritization in Phase 1 has been critical for slowing the spread of the virus and keeping the number of deaths and severe medical complications in our community low.

Our advocacy on the COVID-19 vaccine continues to evolve every day. As the Commonwealth moves into Phase 2 of the vaccination distribution, we ask you to please consider prioritizing our community once again. The Arc recently co-authored a letter with the Center for Public Representation and other disability groups to the Governor and other state officials on January 28th, offering recommendations regarding priority populations, accessible vaccination sites and other important issues related to the vaccination roll out. We want to follow up on this letter to highlight the urgent need for the Commonwealth to prioritize all individuals with I/DD and autism for the vaccine now. Over the last year, medical professionals and research studies have recognized that autism, neurological conditions, acquired brain injury, and I/DD, increase an individual risk of serious complications and death from COVID-19.[1] Not only are individuals with autism or I/DD more susceptible to COVID-19, but these individuals have also disproportionally lost vital educational services, health care resources and experienced employment layoffs. Some individuals with autism or I/DD may also struggle with mask-wearing or adhering to social distancing guidelines.[2] Taken together, the evidence emphasizes that it is critical to vaccinate this population as soon as possible to prevent further harm.

In addition, companions and caregivers of those over 75 who are getting vaccinated in Massachusetts now have access to the COVID-19 vaccine. We ask that this same consideration be made for people accompanying people with autism or I/DD to vaccination sites.  Similarly, to people over 75, an individual with autism or I/DD will likely need a family member, caregiver or other trusted individual to accompany and assist them in navigating the vaccination site and providing support during or after the vaccination. For example, an individual could have difficulty waiting in a long line, not be able to mask or social distance properly or become distressed when the vaccine is administered and therefore need a companion to assist them. It is important that companions and caregivers of people with autism or I/DD have the same type of access to the COVID-19 vaccine.

Further, the accessibility of the vaccination site will be important to people with I/DD and autism as well. All approved vaccination locations should be expected to verify that they understand their obligations under State and federal law to provide physically accessible vaccine administration, and to make reasonable accommodations when necessary to ensure safe and equal access by persons with disabilities. Special considerations may be needed to support people with autism or I/DD at a vaccination site. 

Thank you for your consideration of these time sensitive concerns. If you have any questions, please follow up with Maura Sullivan at sullivan@arcmass.org.

Sincerely,

Leo V. Sarkissian, Executive Director
The Arc of Massachusetts

Michael J. Borr, Chair
Advocates for Autism of Massachusetts


[1] Emily Hotez, Peter J. Hotez, Kashia A. Rosenau, Alice A. Kuo, Prioritizing COVID-19 vaccinations for individuals with intellectual and developmental disabilities, EClinicalMedicine, 2021, 100749, ISSN 2589-5370, https://doi.org/10.1016/j.eclinm.2021.100749. (https://www.sciencedirect.com/science/article/pii/S25895370210002 98)

[2] They have disabilities and serious medical conditions. But under state guidelines, they don’t qualify for early vaccination, The Boston Globe, Deanna Pan, February 12, 2021, available at https://www.bostonglobe.com/2021/02/12/nation/they-have-disabilities-serious-medical-conditions-under-state-guidelines-they-dont-qualify-early-vaccination/