Reviews | I ran the CDC. Here’s how to prove Americans are vaccinated.
This month, President Biden announced a comprehensive plan to re-energize the United States’ fight against the Covid-19 pandemic. Much of this plan rests on the obligation to vaccinate millions of federal workers. Employees of companies with more than 100 employees must provide proof of vaccination or a negative test for the coronavirus at least once a week. Businesses and other institutions that must enforce these mandates will need to verify immunization status and test results to make this system work.
Even before the plan was announced, a number of state and local governments and school districts and more than 1,000 colleges and universities adopted at least some vaccination requirements for employees and students. But without a unified approach to verifying compliance, ideally through federal leadership, verification will be inaccurate, inconsistent, and potentially insecure.
Counterfeit vaccination cards are already in circulation and unvaccinated people are using them to enter spaces where they would not otherwise be allowed, putting others at risk. Different systems may use different definitions of full vaccination or lack essential information such as time since vaccination. And without clear guarantees, digital verification systems could be compromised: vaccination status could be falsified and private health data could be shared publicly.
Unless the Biden administration quickly issues guidelines on creating an accurate, secure and universal Covid-19 vaccination verification system, those mandates will become confused.
So far, the White House has rejected federal audit guidelines. The verification of vaccination in the United States, however, is not new. Each state has an immunization information system, which consolidates immunization records. Each state already requires measles vaccination and other specified vaccines for admission to school. Many hospitals and nursing homes require staff members to prove that they have received an annual influenza vaccine.
But multiple Covid-19 vaccination verification systems, each with its own user interface, validation, data storage, recovery process, and security protocols, will make it difficult to quickly and securely verify vaccination status. Without federal guidelines, different immunization auditors adopt different methods to confirm the identity of individuals, set adequate protection, protect privacy, and confirm immunization status.
We need a system that works. Here are five requirements for such a system.
First of all, it must be precise. Vaccination data specific to Covid-19 must be stored and verified by a computerized immunization information system – essentially an online record of vaccinations that people have received – which allows for sharing between systems. This approach is more precise and would make it easier to verify vaccination status than a digitized version of a paper file. This may be the only version of verification accepted by international travel entities. Identity may need to be verified with a government issued photo ID, such as a driver’s license.
Second, it must be secure and maintain confidentiality. Everyone should be able to control how their personal data is collected, stored and used. Safeguards should ensure that data will not be sold or misused and will only be used for vaccination verification.
Third, there must be several options for people to collect and voluntarily report their immunization status. People who are unwilling or unable to participate in an electronic verification system should be able to use paper vaccination records with additional verification, such as photo ID. Auditors could then compare this information to existing databases. Withdrawing, however, can also mean withdrawing from certain places or activities that require digital proof of vaccination.
Fourth, the system must be accessible in real time, for example when people go through security checks at airports.
Fifth, the system should be used to check the Covid vaccination only. Bundling these checks with past infection status or laboratory tests for infection, or with other health information, would unnecessarily complicate the system and risk violating the confidentiality of unrelated health data.
Fortunately, some existing standards and tools already meet the above criteria. The Biden administration can build on or endorse the excellent work of two existing consortia: the Vaccine Credential Initiative, a large coalition of leaders in technology, health and public health who verify both paper records. and digital, and the Covid Credentials Initiative, which has set a thoughtful standard with a comprehensive and collaborative governance framework for accreditation that protects data privacy and security. The initiatives use technology already adopted by Defense and Veterans Affairs departments, state governments and large corporations.
One of the means of proof is the SMART Health Card framework developed by the Vaccine Credential Initiative. It uses an open source system that is already in use in several states and could be used in many universities, businesses and the military.
Immunization requirements are already there and will continue to expand. We need to make verification systems accurate, secure and fair. To create such systems, we need appropriate, reliable and consistent national standards to guide them – and we need those standards soon.
Tom Frieden, who was the director of the Centers for Disease Control and Prevention from 2009 to 2017, oversaw the US response to the outbreaks of H1N1, Ebola and Zika. He is the Managing Director of Resolve to Save Lives, a nonprofit organization that focuses on public health.