AVAC Makes Recommendations to the Biden Administration on Immunization Infrastructure Systems (IIS)

AVAC sent a letter to the White House with recommendations on how best to implement the $7.5 billion provided to immunization infrastructure through the American Rescue Plan. The letter outlined guidance from the IIS Modernization Act (H.R. 550) to help the administration meet the challenge of tracking and administering COVID-19 vaccinations.

Dear President Biden, 

The COVID-19 pandemic has taken a devastating toll on our society. With more than 400,000 American lives lost, millions of people forced to file for unemployment, and too many children falling behind in school during online instruction. As the national strategy for the efficient, effective, and equitable distribution of the COVID-19 vaccines moves forward, immunization data systems are proving to be a critical tool in the success of this effort. 

We were pleased to see the American Rescue Plan Act of 2021 includes robust support for immunization infrastructure, including $7.5 billion for activities to plan, prepare for, promote, distribute, administer, monitor, and track COVID–19 vaccines. We wish to build upon the directive to provide technical assistance, guidance, and support to, and award grants or cooperative agreements to, State, local, Tribal, and territorial public health departments for enhancement of COVID–19 vaccine distribution and administration capabilities. Specifically, we wish to highlight the importance of “information technology, data, and reporting enhancements, including improvements necessary to support sharing of data related to vaccine distribution and vaccinations and systems that enhance vaccine safety, effectiveness, and uptake, particularly among underserved populations.” 

While most health departments have immunization infrastructure in place, they need an infusion of support now to operationalize pandemic immunization efforts. Immunization information systems (IIS) are computerized, multi-faceted systems that operate in 62 jurisdictions, and have the ability to maintain immunization records across the lifespan. They can be used by providers to order vaccines and track inventory, view patients’ previous vaccine to ensure they are fully vaccinated but not over-vaccinated, remind patients when they are due to receive a recommended vaccine, and, at a population level, track coverage and identify areas where there are low immunization rates so public health programs can develop targeted immunization efforts in response. 

We know for instance that race/ethnicity is known for just over half (55%) of people who had received at least one dose of the vaccine. Among this group, nearly two thirds were White (63%), 9% were Hispanic, 6% were Black, 5% were Asian, 2% were American Indian or Alaska Native, and <1% were Native Hawaiian or Other Pacific Islander, while nearly 14% reported multiple or other race. Under the President’s January 20th executive order to “Advance Racial Equity and Support for Underserved Communities through the Federal Government, it should not be simply enough to understand the trends when with proper investment we can pinpoint the individuals in communities of color that aren’t being served and take action to serve them. 

However, IIS capabilities today vary vastly across states and many systems desperately need support to meet the challenges of a Covid-19 mass vaccination campaign, especially to track coverage and identify areas where there are low immunization rates so public health programs can develop targeted immunization efforts in response. Without investments in immunization infrastructure – IIS in particular – the racial and geographic disparities in vaccination take-up are hard to track and eradicate. 

We ask that you look to the framework set out in the “IIS Modernization Act, H.R. 550” for additional guidance on how to enhance systems to manage “routine” immunization efforts and outbreaks of other vaccine preventable diseases. Among other things, the bill would authorize funding for the following activities: 

  • An assessment of current capabilities and gaps among immunization providers; 
  • Expand enrollment and training of immunization providers; 
  • Support real-time immunization record data exchange and reporting; 
  • Improve secure data collection, transmission, bidirectional exchange, maintenance, and analysis of immunization information; 
  • Enhance security of bidirectional exchange of immunization record data and interoperability of immunization information systems with health information technology platforms; and 
  • Enhance data exchange interoperability with other jurisdictions. 

We recommend the Administration to use these funds to improve, enhance, and expand the ability of IIS to securely exchange real-time immunization record data between federal health agencies, state, local, tribal, and territorial public health programs and providers across health care settings. Again, thank you for your consideration. 


American Academy of Family Physicians
American Heart Association
American Lung Association
American Public Health Association
Families Fighting Flu
Hepatitis B Foundation/Hep B United
Immunization Action Coalition
National Consumers League
National Hispanic Medical Association
STChealth LLC
The AIDS Institute
The Gerontological Society of America
Trust for America’s Health
Vaccinate Your Family