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From: "Marks, Peter"
To: "Forshee, Richard" >
Cc: "Anderson, Steven" >, "Witten, Celia (CBER)"
Subject: RE: Contact from Ana Szarfman
Date: Tue, 13 Jul 2021 18:14:15 +0000
Importance: Normal
Inline-Images: image001.png; image002 jpg; image003.jpg; image004.jpg:; image005.jpg; image006.jpg
Dear Rich,
Thanks so much for documenting this. | will follow up appropriately.
Best Regards,
Peter
Sent: Tuesday, July 13, 2021 1:55 PM
To: Marks, Peter >
Cc: Anderson, Steven >; Witten, Celia (CBER) <i>
Subject: Contact from Ana Szarfman
Dear Peter,
Ana Szarfman called me at about 4:15pm on Friday 7/9. She said that she and Bill DuMouchel had found an increased risk
of mortality following COVID-19 vaccination using data mining methods. | asked her to send me the analysis and promised
to review it, and I’ve attached the email she sent on Monday 7/12. It has very little information on the methods. I’ve
pasted my reply to her below.
lam very concerned that whatever association they think they have identified is spurious based on the way the COVID-19
vaccination program prioritized individuals and the required and stimulated reporting we are seeing with the COVID-19
vaccines. Ana said that she had taken her name off a publication that is being prepared.
Please let me know how you would like us to proceed.
Best Regards,
-Rich
‘Response to An:
Hi Ana,
Thanks for sharing this, and my team will review it. Do you have any more details on the new methods that Bill
DuMouchel is using? That would be helpful in our evaluation.
In the email thread, Bill asked, “Can anyone propose theories of what potential biases are causing them to have
such high disproportionalities? We hoped that use of AgeGroup11 would eliminate the main bias.”
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During the time frame of this analysis, people with high-risk medical risk conditions were prioritized for
vaccination. This included people in Nursing Homes early in the rollout. In later phases, most people needed to
demonstrate that they had a high-risk medical condition to qualify for a vaccination. These included conditions
like diabetes, chronic lung diseases, hypertension, heart conditions, obesity, and liver disease. Unless Bill has
controlled for this somehow, | worry that the disproportionality in these results is caused by selection bias.
What are your thoughts on this possibility?
Best regards,
--Rich
End
of
Respons:
Richard Forshee, Ph.D.
Acting Deputy Office Director, CBER/OBE
Center for Biologics Evaluation and Research
Office of Biostatistics and Epidemiology
Analytics and Benefit-Risk Assessment Team
U.S. Food and Drug Administration
PN
U.S.
FOOD
& DRUG
ADMINISTRATION
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From: "Szarfman, Ana”
To: "Forshee, Richard”
Subject: RE: Findings ofinterest to the Division
Date: Fri, 11 Jun 2021 14:22:41 +0000
Importance: Normal
Attachments: CDER_Clearance_Request_for_Articles_Speeches_and_Other_Publications_Masking Associated_with Early COVID-19_Vaccine_Safety_Surveillance pdf,
PDS_-_COVID19_safety_surveillance_and_masking docx
Inline-Images: image001 jpg; image002 jpg
Hi
Richard,
Please referto the feedback by Ellis regarding the FDA/CDC AC on covid-19 vaccines held yesterday, and to the RGPS finding of AMI in the public domain data of2 months ago, as well as to a
methodological paper on RGPS that | am forwarding.
We would love to have you as a collaborator.
‘Many thanks, Ana
Sent: Friday, June 11, 2021 9:52 AM.
‘To: Szarfman, Ana >
Subject: RE: Findings of interest to the Division
Impressive, Ana! Did you send thisto Richard Forshee in CBER? He's involved (and may lead) CBER’s post-marketing/pharmacovigilance office/division. He's mathematically oriented (| think he’s a
statistician by training). He'd be extremely interested in this.
Sent: Friday, June 11, 2021 9:16 AM.
‘To: Unger, Ell
EE 50550-5000 00:0, TT
Hi
Dear
Ellis,
‘You may be already aware that the main topic of discussion of FDA/CDC AC on covid-19 vaccines held yesterday was myocardial events and the lack of signals in VAERS and other data resources.
1am not astonished that MGPS was unable to detect these signals.
In contrast, in the email that | am forwarding, that | originally send over a month ago, we documented that RGPS signals AMI. (We also detected clear signals for other similar events). Notice that we
used public domain data posted about2 months ago.
From: Szarfman, Ana
Sent: Thursday, May 6, 2021 6:52 PM
Ce: bill.dumouchel
Subject: Findings of interest to the Division
Hi
Norman
and Aliza,
‘Two issues of interestto the Division:
First, A signal of Acute Myocardial Infarction with COVID-19 vaccines in VAERS that was unmasked by RGPS.
Referto the first screen shot that | pasted below. The analysis was performed by Bill using public domain data.
Note that the EROS signals of RGPS are higher than the EBOS signals of MGPS.
This is, of course an early signal that we are monitoring.
Second, the lower rate of coverage of the Pfizer vaccine against symptomatic infection in patients with CHF or CKD
Referto the second screen shot.
Ran Balicer, the director of the COVID-19 vacci
2021. DOI: 10.1056/NEIMc2104281,
in Israel described these findings during the Parallel Accelerator meeting of today. These are findings put
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New Engl J Med 2021. DOI: 10.1056/NEJMc2104281
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AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
CDER Clearance Request for
Articles, Speeches, and Other
Publications
Date of Request
06/03/2021
If clearance is requested to meet a deadline,
please provide deadline date.
06/08/2021
1. Person to Contact
Ana Szarfman
2. Phone Number 3. Email address
4. Title of Article, Speech, or Other Publication
Masking Associated with Early COVID-19 Vaccine Safety Surveillance
5. Authors
DuMouchel W.1, Harpaz R.1*, Szarfman A.2, Van Manen R.1, Nip A.1, Bright S.1, Al-Ansari M1
6. Author Affiliations
1. Oracle Health Sciences, Bedford, MA, United States; 2. Division of Cardiology and Nephrology, OCHEN, OND, CDER, FDA
7. Details of Article or Speech
Li Regulatory Summary‘ Letter Journal
Journal Article ie ti "
v 1 Review Article Editorial | pnarmacoepidemiology and Drug Safety’
Peer Reviewed Research
] Chapter Title Book Title
Book Chapter
Meeting Abstract | Meeting Title ‘Meeting Sponsor ‘Meeting Date Meeting Location
Symposium/
Workshop
"i Talk Title Meeting Sponsor Meeting Date Meeting Location
Submitter Assurances
8. This article or speech was completed as: Assigned Work
9. The article or speech is a result of research involving human subjects, specimens, or subject level data (e.g., NDA data)? © Yes @ No
If yes — Please provide Research Involving Human Subjects Committee (RIHSC) Protocol Number
10. If the article or speech is reporting the results of CDER research, all of the methodological details, analytical
procedures, and underlying source data supporting the conclusions are documented and available for inspection?
11. To the best of my knowledge, this article or speech NOT contains
12. Tothe best of my knowledge, the statements and conclusions in this article or speech conform with FDA policy.
non-public information.
13. The following divisions and offices have reviewed this article or speech:
14, Submitter Signature (digital) Ana Szarfman -S
©
Yes
©
No
@ Yes ONo
Review and Clearance
14. First Line Reviewer
Name
‘Signature (digital) Date
Free
of
non-public
information
Select
(optional - by office)
Conforms with FDA policy _— Select.
18. Second Line Reviewer | Free of non-public information ‘ Name ‘Signature (digital) Date
( I by ) Conforms with FDA policy select
16. Clearance Official
Free
of
non-public information select
Conforms with FDA policy select.
‘Comments
Article or Speech is:
Lcieared [)Not Cleared [] Returned for Revisions Is a disclaimer required? select one (if Yes, [] Disctaimer 1 [Disclaimer 2)
Name Signature (digital) Date
SAVE FORM
CLEAR FORM
|
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Masking Associated with Early COVID-19 Vaccine Safety Surveillance
DuMouchel W.1, Harpaz R.1*, Szarfman A.2, Van Manen R.1, Nip A.1, Bright S.1, Al-Ansari M1.
1 Oracle Health Sciences, Bedford, MA, United States
2 U.S. FDA, Silver Spring, MD, United States
* Corresponding author
Abstract:
Purpose: raise awareness to the problem of masking associated with early stage VAERS COVID-19 vaccine
surveillance, which can lead to missed signals. Provide a preliminary investigation of these masking effects.
Methods: three signal detection methodologies: MGPS, PRR, and a new methodology called RGPS that can
control masking were applied to six years of VAERS reports, consisting of 17 weeks of COVID-19 vaccine
reports.
Results: several statistically masked associations are identified, some of which are also listed in the product
labels and reported in clinical trials. The most extreme case of masking is statistically verified by removing
reports containing the ‘offending’ masker. RGPS appears to provide a reasonable middle ground between
MGPS and PRR with respect to the veracity and number of signals produced by each methodology.
Conclusions: statistical masking is present and should be considered in the context of early stage COVID-
19 signal detection. RGPS can address masking and confounding effects, which cannot be properly
controlled by conventional signal detection methodologies.
Purpose:
As the world contends with rolling out massive scale vaccination programs to end the COVID-19 pandemic,
identifying and studying adverse events related to these vaccines is critically urgent. The Vaccine Adverse
Event Reporting System (VAERS), co-administered by the US Food and Drug Administration and the
Centers for Disease Control and Prevention (CDC), is one of several systems used to monitor adverse
events that occur after vaccination, including the COVID-19 vaccine. Like other safety surveillance
systems, VAERS offers the opportunity to rapidly flag potential safety issues related to vaccines–a process
usually known as signal detection.
Computational methodologies for signal detection have been routinely applied to safety surveillance
systems for over 20 years and have become a de facto standard[1]. Given its impact on public health,
signal detection is still an active area of research, and since its conception multiple guidances[2-5] have
been published with practice recommendations as well as admonitions concerning data and
methodological limitations.
In particular, ‘masking’ is a problem that may result in missed signals. Masking[3, 6, 7] is an artifact of
conventional disproportionality statistics used for signal detection that are based on 2x2 contingency
tables. A masked relationship between a target product and target adverse event can emerge when
another product/s is frequently reported with the target event while making the background rate for the
target event considerably large. This larger background rate can then make the relationship between the
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target product and the target event appear less unusual, hence masking the true relationship. Conditions
that make signal detection especially vulnerable to masking effects include: smaller volume of cases such
as in VAERS, relationships involving rare events, and relationships involving newer products (i.e., emerging
signals). As such, the early stages of COVID-19 vaccine surveillance makes signal detection especially
susceptible to masking.
Masking effects can be ameliorated by removing cases containing the ‘offending’ product, by using
stratification, and by employing regression techniques, all of which require to some extent identifying
masking sources prior to signaling.
Regression-Adjusted GPS (RGPS)[8] is a signal detection methodology that is designed to combine the
application simplicity of conventional signal detection methodologies with the power of regression to
produce disproportionately statistics with adjusted background rates. Among other, these adjusted
background rates can control masking effects.
The purpose of this report to raise awareness to masking in the context of early stage VAERS COVID-19
vaccine surveillance and provide a preliminary investigation of these masking effects using the RGPS
methodology.
Methods:
Data: The investigation was done using VAERS reports from Jan. 01, 2015 to May 01, 2021–the latest
public release of VAERS data available at the time of writing. This data represents 17 weeks of COVID-19
vaccine reports, and 6 years of other vaccine reports used as background. In total 466,401 reports were
used. Of those 145,300 reports included the COVID-19 vaccine from three manufacturers:
Pfizer/BionTech (39.6%), Moderna (45.9%), and Janssen (14.5%). Events were represented at the MedDRA
Preferred Term (PT) level. To investigate adverse events commonly reported across the three
manufacturers, products were represented at the ‘vaccine type’, e.g., ‘COVID19’ rather than at the
‘manufacturer’ level, e.g., ‘COVID19_PFIZER/BIONTECH’.
Methods: The RGPS methodology operates by fitting separate Bayesian logistic regression models to each
target adverse event. RGPS automatically selects two types of predictors to be included in each regression
model: (1) products that are statistically associated with the target event, which are represented as
indicator variables, and (2) stratification categories grouped by target event rates, which are represented
as multiple regression intercepts. Rather than using the fitted regression coefficients to compute signal
scores (disproportionalities), RGPS computes observed to expected ratios of counts similar to
conventional methodologies. The expected counts are computed by summing the regression predicted
probabilities of the target event across all reports mentioning the target product under the null hypothesis
of no association between the target product and target event. The null hypothesis probabilities are
computed by setting the coefficient of the target product to zero if selected as a model predictor. This
results in adjusted expected counts (background rates) that can address masking. The final signal score
(and its intervals) are computed using Bayesian shrinkage of observed to expected counts similar to
MGPS[9]. Complete details of the RGPS methodology are presented in reference[8].
The results of RGPS were compared against those of the MGPS and the PRR[10] methodologies.
Stratification categories used for RGPS and MGPS were: age (10 levels) and gender (3 values). Stratification
by ‘report year’ could not be applied because COVID-19 VAERS reports dominate reporting from
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December 2020. We applied the canonical version of PRR, which does not require stratification. For RGPS
and MGPS we generated both the point estimates, labeled ERAM and EBGM respectively, and their
associated credible intervals labeled ER05-ER95 and EB05-EB95 respectively. Unless specified otherwise,
signal scores are represented by the point estimates. The generation of signal scores for the three
methodologies and analysis thereof was done using Oracle Empirica Signal 9.1[11].
Results:
Figure 1 provides a high-level comparison of signal scores generated by RGPS, MGPS, and PRR for COVID-
19 vaccine-related adverse events. The comparison is illustrated by means of sector (heat) maps.
The figure positions RGPS as a compromise between PRR and MGPS with respect to the number of signals
produced by each methodology. Setting the signal score cutoff to 2, PRR produced 3,695 signals, whereas
RGPS 467 signals, and MGPS 74. Setting the cutoff to 5, PRR produced 1,492 signals, whereas RGPS 74
signals, and MGPS only 7. The canonical version of PRR is generally known to produce more signals at the
expense of possibly a larger number of false alerts compared to MGPS, but as a result may miss fewer
signals than MGPS. Which of the methods provides a better tradeoff is still a subject of debate, and beyond
the scope of this report.
We conjecture that the larger number of signals produced by RGPS compared to MGPS is due to masking.
Both RG*PS and PRR show a ‘hot’ zone of cardiac events some of which were recently highlighted by the
CDC[12].
Figure 1. Sector-map comparison of signal scores generated by RGPS, MGPS, and PRR for COVID-19 vaccine-related adverse
events. The major rectangular areas represent system-organ-classes (SOCs) and the smaller interior rectangles represent
preferred terms (PTs). The box sizes represent the number of cases, and colors represent the size/scale of signal scores, ranging
from green-smaller scores to red-larger scores.
Table 1 provides signal statistics for the top 20 masked COVID-19 vaccine associations flagged by RGPS. A
candidate association for masking is defined as one whose signal statistics satisfy the following condition:
ER05 > EB95 and ER05 > 1 and EB05 < 1
That is, an association where RGPS and MGPS disagree by producing non-overlapping credible intervals
(ER05 > EB95) with RGPS’ interval above the boundary of no association (ER05>1) and that of MGPS below
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or including the boundary of no association (EB05 < 1). The associations are ranked by the magnitude of
the masking effect, which we define as the ratio of RGPS’ and MGPS’ signal scores, i.e., ERAM/EBGM. The
table also provides signal scores for the IC statistic[13], which were close to those of MGPS.
Several of the adverse events listed in Table 1 have been listed in the product labels and reported in clinical
trials[14], and others are known issues associated with vaccine administration. While the size of the signal
scores in Table 1 would normally not be considered large enough to warrant immediate action, they
nonetheless clearly illustrate the masking effect. Herpes zoster (shingles, 903 reports) was ranked highest
in terms of the masking ratio equal to 1.20/0.31=3.91. PRR produced a signal score of 0.17 for the same
association. RGPS automatically selected 39 product predictors and 16 stratification groups for the Herpes
zoster regression model (the ‘COVID19’ vaccine type was not one of the predictors). The strongest
predictor and likely the culprit for masking was the VARZOS vaccine--a combination vaccine of Varicella
and Zoster. Upon removal of all reports containing the VARZOS vaccine (the alternative approach for
controlling masking) the PRR and EBGM signal scores reverted to 1.76 and 1.12 respectively, supporting
RGPS’ finding of the offending masker. Herpes zoster has also been reported in an observation study[15].
Table 1.Top 20 masked COVID-19 vaccine associations flagged by RGPS. N: number of reports with the adverse event and
COVID-19. E_RGPS: adjusted expected counts produced by RGPS. ERAM: signal score produced by RGPS. ER05/ER95: lower and
upper bounds of RGPS’ credible intervals. E_MGPS: adjusted expected counts produced by MGPS. EBGM: signal score produced
by MGPS. EB05/EB95: lower and upper bounds of MGPS’ credible intervals. PRR: signal score produced by PRR. 2^IC: 2 to the
power of the signal score produced by the IC calculation. Masking ratio: ERAM/EBGM.
Event (MedDRA PT) N E_RGPS ER05 ERAM ER95 E_MGPS EB05 EBGM EB95 PRR 2^IC Masking
Ratio
Herpes zoster 903 752.2 1.14 1.20 1.27 2940.2 0.29 0.31 0.33 0.17 0.31 3.91
Numb chin syndrome 10 1.8 2.63 4.79 7.46 5.2 0.96 1.58 2.49 41.28 1.85 3.03
Cholecystitis acute 10 1.8 2.64 4.80 7.48 5.1 0.96 1.58 2.50 41.28 1.86 3.03
Influenza virus test
negative
354 303.6 1.07 1.17 1.27 497.4 0.65 0.71 0.78 0.52 0.71 1.64
Pneumonia 612 462.3 1.24 1.32 1.41 712.6 0.80 0.86 0.92 0.60 0.86 1.54
White blood cell count
increased
491 432.6 1.05 1.14 1.22 619.3 0.74 0.79 0.85 0.62 0.79 1.43
Underdose 468 345.8 1.25 1.35 1.46 488.1 0.89 0.96 1.03 0.70 0.96 1.41
Syringe issue 313 209.9 1.35 1.49 1.63 289.0 0.98 1.08 1.18 1.11 1.08 1.38
Oral herpes 247 188.0 1.18 1.31 1.45 259.1 0.86 0.95 1.06 1.28 0.95 1.38
Sepsis 192 127.5 1.33 1.50 1.68 175.3 0.97 1.09 1.23 0.82 1.10 1.37
Product administered
to patient of
inappropriate age
1132 908.9 1.19 1.25 1.31 1158.6 0.93 0.98 1.03 0.38 0.98 1.27
Abdominal discomfort 1262 1038.9 1.16 1.21 1.27 1272.1 0.95 0.99 1.04 1.41 0.99 1.22
Head injury 344 274.0 1.15 1.25 1.37 333.3 0.94 1.03 1.13 0.83 1.03 1.22
Seizure 884 818.0 1.02 1.08 1.14 986.4 0.85 0.90 0.95 0.42 0.90 1.21
Disturbance in
attention
431 382.2 1.04 1.13 1.22 454.8 0.87 0.95 1.02 0.95 0.95 1.19
Pallor 1171 1029.9 1.08 1.14 1.19 1219.7 0.92 0.96 1.01 0.58 0.96 1.18
Vaccination site
swelling
569 516.3 1.03 1.10 1.18 609.5 0.87 0.93 1.00 0.96 0.93 1.18
Syncope 2666 2292.0 1.13 1.16 1.20 2681.5 0.96 0.99 1.03 0.87 0.99 1.17
Rash pruritic 1838 1640.8 1.08 1.12 1.16 1880.6 0.94 0.98 1.02 1.39 0.98 1.15
Loss of consciousness 2259 1947.6 1.12 1.16 1.20 2213.4 0.99 1.02 1.06 0.97 1.02 1.14
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Conclusion:
The novelty and early stages of COVID-19 vaccine surveillance, compounded by the size of the VAERS
database predisposes signal detection to the notorious masking effect. Left unattended masking could
lead to costly missed signals. This report demonstrates that statistical masking is indeed present and at
the very least should be considered in the context of COVID-19 signal detection. The report also
demonstrates the potential utility of a new signal detection methodology called RGPS that can address
masking and confounding effects that cannot be properly controlled by conventional signaling
methodologies. Signal detection is inherently exploratory, therefore the associations named in this report
do not imply causal relationships.
Disclaimer:
The findings and conclusions expressed in this report are those of the authors and do not necessarily
represent the views of the U.S. FDA or the federal government.
Competing financial interests:
The authors declare no competing financial interests. DuMouchel W., Harpaz R., Van Manen R., Nip A.,
Bright S., Al-Ansari M. are employed by Oracle Health Sciences.
References:
1. Szarfman, A., S.G. Machado, and R.T. O'Neill, Use of screening algorithms and computer systems
to efficiently signal higher-than-expected combinations of drugs and events in the US FDA's
spontaneous reports database. Drug Saf, 2002. 25(6): p. 381-392.
2. Wisniewski, A.F.Z., et al., Good Signal Detection Practices: Evidence from IMI PROTECT. Drug
Safety, 2016. 39(6): p. 469-490.
3. Almenoff, J., et al., Perspectives on the Use of Data Mining in Pharmacovigilance. Drug Safety,
2005. 28(11): p. 981-1007.
4. CIOMS Working Group VIII. Practical Aspects of Signal Detection in Pharmacovigilance. 2010:
CIOMS.
5. Guidance for Industry: Good Pharmacovigilance Practices and Pharmacoepidemiologic
Assessment U.S. Department of Health and Human Services. Food and Drug Administration.
Center for Drug Evaluation and Research (CDER)Center for Biologics Evaluation and Research
(CBER) March 2005 https://www.fda.gov/media/71546/download.
6. Maignen, F., et al., Assessing the extent and impact of the masking effect of disproportionality
analyses on two spontaneous reporting systems databases. Pharmacoepidemiol Drug Saf, 2014.
23(2): p. 195-207.
7. Juba, K.M., R.P. van Manen, and S.E. Fellows, A Review of the Food and Drug Administration
Adverse Event Reporting System for Tramadol-Related Hypoglycemia. Ann Pharmacother, 2020.
54(3): p. 247-253.
8. DuMouchel, W. and R. Harpaz, Regression-adjusted GPS algorithm (RGPS), in Oracle White
Paper, https://docs.oracle.com/health-sciences/empirica-signal-811/ESIUG/Regression-
Adjusted_GPS_Algorithm.pdf. 2012.
9. Dumouchel, W., Bayesian Data Mining in Large Frequency Tables, with an Application to the FDA
Spontaneous Reporting System. The American Statistician, 1999. 53(3): p. 177-190.
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10. Evans, S.J.W., P.C. Waller, and S. Davis, Use of proportional reporting ratios (PRRs) for signal
generation from spontaneous adverse drug reaction reports. Pharmacoepidemiology and Drug
Safety, 2001. 10(6): p. 483-486.
11. Oracle Empirica Signal. https://docs.oracle.com/en/industries/health-sciences/empirica-
signal/9.1/index.html. 2021.
12. Myocarditis and Pericarditis after Receipt of mRNA COVID-19 Vaccines.
https://content.govdelivery.com/attachments/MDMBP/2021/05/28/file_attachments/1839782/
Clinician%20Letter_Myocarditis_5.28.21.pdf. 2021.
13. Bate, A., et al., A Bayesian neural network method for adverse drug reaction signal generation.
Eur J Clin Pharmacol, 1998. 54(4): p. 315-21.
14. DailyMed, COVID-19 Vaccine Product Labels.
https://dailymed.nlm.nih.gov/dailymed/search.cfm?labeltype=all&query=COVID-19+vaccine.
2021.
15. Furer, V., et al., Herpes zoster following BNT162b2 mRNA Covid-19 vaccination in patients with
autoimmune inflammatory rheumatic diseases: a case series. Rheumatology, 2021.
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From: "Marks, Peter"
To: "Anderson, Steven" >, "Forshee, Richard"
"Stockbridge, Norman L" , "Dal Pan, Gers a”
>,
"Witten,
Celia
(CBER)"
Cc: "Jenkins, Charlene"
Subject: FW: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System
Running
Date: Sun, 14 Feb 2021 19:01:07 +0000
Importance: Normal
Attachments: NYT_--
_As MillionsGet_Covid_Vaccine_Shots, F.D.A. Struggles With _Safety_Monitoring.pdf
Inline-Images: image001.png
Dear Al,
Based on Ana’s incoming, Charlene will set up an hour sometime in the next few weeks for us to discuss her concerns and
recommendations. Thanks.
Best Regards,
Peter
Sent: Sunday, February 14, 2021 9:31 AM
To: Marks, Peter >
Ce: Stockbridge, Norman L >
Subject: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
Hi Peter.
Thanks so much for your work.
Regarding the NYT article, | am quite concerned that the distributed network of EHRs that the
Sentinel System uses does not have mortality data, and that they (and we) are not clamoring to
fix this problem. It still takes several years to collect mortality data. Indeed there are no
incentives to update electronic health records with mortality data.
https://www.nytimes.com/2021/02/12/health/covid-vaccine-how-safe.html?
referringSource=articleShare
> Let me know if you want Bill DuMouchel and | to discuss our proposal for more effective
monitoring, including the need to use an updated algorithm by DuMouchel for data mining
spontaneous reports at CDER and CBER.
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Many thanks,
--Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical
Informatics (2017), and Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
Celebrating nearly a quarter of a century of successful implementation of safety data mining,
interactive patient profiles, and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food
and Drug Administration
PLN
U.S.
FOOD
& DRUG
ADMINISTRATION
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oO |
The Coronavirus
Outbreak >
Latest Updates
Maps and Cases
See Your Local Risk
New Variants Tracker
Vaccine Rollout
As Millions Get Shots, F.D.A. Struggles
to Get Safety Monitoring System
Running
For now, the government has been relying on a patchwork of
programs that officials say are hampered by limited size and gaps in
data collection.
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As Millions Get Covid Vaccine Shots, F.D A. Struggles With Safety Monitoring - The New York Times
https://www.nytimes.com/2021/02/12/health/covid-vaccine-how-safe.html?referringSource=articleShare[2/14/2021 8:52:03 AM]
By Sheila Kaplan
Feb. 12, 2021
More than 35 million Americans have received Covid vaccines, but the
much-touted system the government designed to monitor any dangerous
reactions won’t be capable of analyzing safety data for weeks or months,
according to numerous federal health officials.
For now, federal regulators are counting on a patchwork of existing
programs that they acknowledge are inadequate because of small sample
size, missing critical data or other problems.
Clinical trials have shown both of the vaccines authorized in the United
A drive-through mass vaccination site at Coors Field baseball stadium in Denver last month. Chet Strange/Agence France-
Presse — Getty Images
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States — one from Pfizer-BioNTech and the other from Moderna — to be
highly protective and safe against the coronavirus.
But even the best trials have limited ability to detect adverse reactions that
are rare, those that only occur in certain population groups, or which
happen beyond the three-month period studied in the trials. Tracking
adverse events once the vaccines are administered to the public at large is
essential not just to detect problems but to build confidence in the safety of
vaccines.
In interviews, F.D.A. officials acknowledged that a promised monitoring
system, known as BEST, is still in its developmental stages. They expect it
to start analyzing vaccine safety data sometime soon — but likely not until
after the Biden administration reaches its goal of vaccinating 100 million
people.
“I’m concerned about this disjointed tracking system,” said Dr. Ashish K.
Jha, dean of the Brown University School of Public Health. “We knew these
vaccines were coming for at least several months before they got
authorized, so we really should have had a well-developed system.”
Dr. Jha and others believe that with all the public attention on the vaccines,
any serious adverse reactions will likely be reported somewhere. But, they
say, a more systematic approach is crucial.
“It’s critical to track, because it will help build confidence,” Dr. Jha said.
Monitoring is all the more important because the vaccines were developed
and approved in record time, with the goal of inoculating most of the U.S.
population as quickly as possible.
“It’s the right thing to do, but the fact of the matter is we don’t have enough
information and we’re desperately in need of post-market information and
monitoring,” said a high-ranking F.D.A. official, who asked not to be
named because he was not authorized to discuss the matter publicly.
The government is now relying most on a 30-year-old safety monitoring
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system that the F.D.A. shares with the Centers for Disease Control and
Prevention, and a new smartphone app that people who get vaccinated can
download and use to report problems if they wish. The C.D.C. also runs the
Vaccine Safety Datalink, a collaboration between the agency and nine
health systems that collects vaccine data and electronic medical records of
roughly 12 million patients. Although it is well-regarded, it is of limited use
because of its small size.
“It’s great for routine stuff, but when it comes to safety surveillance, it’s all
about size,” said Dr. Daniel Salmon, director of the Institute for Vaccine
Safety at Johns Hopkins University, and a former federal vaccine official.
“The bigger it is, the faster you get an answer. Eventually the VSD will get a
really good answer — probably one of the best answers of anybody out
there because they are so good at doing it. But in a pandemic, time isn’t on
our side.”
Boxes of the Pfizer-BioNTech vaccine were prepared for shipment at a facility in Portage,
Mich., in December. Pool photo by Morry Gash
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So far, few serious problems have been reported through these channels
and no deaths have conclusively been linked to the vaccines. The 30-year-
old initiative, known as the Vaccine Adverse Event Reporting System, or
VAERS, relies on self-reported cases from patients and health care
providers.
Health officials say that so far, the two vaccines already authorized for use
appear to be quite safe. There have been a few severe allergic reactions,
including anaphylaxis, but they are treatable and considered rare. The rate
at which anaphylaxis has occurred so far — 4.7 cases in every million doses
of the vaccine by Pfizer and BioNTech, and 2.5 cases per million for the
vaccine by Moderna — are in line with what happens with other widely
used vaccines.
The Coronavirus Outbreak ›
Latest Updates ›
Updated
The televangelist Frederick K.C. Price has died at 89 of complications
from Covid-19.
F.D.A. officials say their ‘flawed’ policy led to a flood of unreliable
antibody tests early in the pandemic.
Peru has a new health minister after a vaccine scandal forced the
previous one to resign.
Bruising and bleeding caused by lowered platelet counts have also been
reported, though it is not known if they are linked to the vaccines, or
coincidental. In total, 9,000 adverse events were reported, with 979 serious
and the rest classified as nonserious, according to the most recent C.D.C.
report available.
In interviews, public health experts, including current and former officials
at the F.D.A. and the C.D.C., expressed a need to improve upon old
“passive” surveillance, which depends on self-reporting. They said that
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funding shortages, turf wars and bureaucratic hurdles had slowed
preparing BEST, formally called the Biologics Evaluation Safety Initiative,
to monitor the Covid vaccines.
An earlier version of BEST was started in 2017, to improve the F.D.A.’s
tracking of new blood products and vaccines, but the agency has only used
it on a limited basis. It is considered an “active” surveillance system
because scientists can use data collected from clinical care to hunt for
safety problems, rather than rely on individuals to report health problems
that they believe — but often without proof — were caused by the vaccine.
BEST is part of the agency’s move toward using more real-world evidence
to vet new products or monitor them after approval. The F.D.A. has done
some preliminary studies using BEST to evaluate the safety of shingles and
flu vaccines.
When the monitoring system is fully up and running, the F.D.A. expects to
have access to more than 100 million individual medical records, and will
be able to look for signs of safety problems, and then determine whether
they are real. But critics say it is folly for the F.D.A. to be launching a new
system in the midst of a pandemic. And several C.D.C. officials said the
F.D.A. was not giving them a real sense of when the complex system would
begin to work.
“It’s been a puzzle to me,” said one C.D.C. official who was not authorized
to discuss the issue and asked not to be identified. “F.D.A. talks about this
in a way that is really unclear as to what is up and ready to go and what
isn’t.”
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The headquarters of the F.D.A. in Silver Spring, Md. Jim Lo Scalzo/EPA, via Shutterstock
But even BEST will suffer from a data problem that is already hindering
existing systems: the dearth of health insurance claims to show who got
which vaccine, and when. Typically health care providers and patients
submit such claims to insurers, but with the vaccines being given at no
charge, often at government-sponsored events, few are bothering to file
claims. Critics say that federal health officials should have predicted this
glitch and prepared for it.
“The current safety surveillance system in the U.S. is dependent on health
insurance claims data and electronic health records,” said Dr. Salmon. “If
the vaccine data information doesn’t get into the safety system, then that
safety system is unable to function.”
Covid-19 Vaccines >
What You Need to Know About the Vaccine Rollout
Providers in the U.S. are administering about 1.3 million doses of Covid-19 vaccines
per day, on average. Almost 30 million people have received at least one dose, and
about 7 million have been fully vaccinated. How many people have been vaccinated
in your state?
The U.S. is far behind several other countries in getting its population vaccinated.
In the near future, travel may require digital documentation showing that
passengers have been vaccinated or tested for the coronavirus.
ine? ine’ cide affacte? Is it caf:
In December, the C.D.C. launched V-safe, a smartphone-based system that
checks in with individuals who get the Covid vaccine to monitor for side
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effects. Roughly two million people who have been vaccinated have
enrolled, a small fraction of the total number, and of those, one million
have responded to text queries and surveys about their post-vaccine health.
At a recent C.D.C. advisory meeting, Dr. Tom Shimabukuro, who oversees
Covid-19 vaccine safety for the agency, said he was pleased that the new
app had enrolled so many users, but he also acknowledged problems like
errors that indicated men and older women to be listed as pregnant.
It’s also unclear how heartily vaccine providers are promoting V-safe. Some
health care providers send post-vaccine emails to patients noting its
availability, and others merely put a stack of C.D.C. fact-sheets about V-safe
in the vaccination room and hope patients pick it up. Even Dr. Jha said he
didn’t sign up for it.
Still, Dr. Shimabukuro said he was confident in the current surveillance
system. “For the national Covid-19 vaccination program, we have
implemented the most intense safety monitoring in the history of the
United States,” he said. “We have multiple systems that are complementary
to each other, that are able to rapidly collect information, that are able to
rapidly assess the safety of immunizations.”
Medical workers filled doses of Moderna’s vaccine at a a drive-through site in Robstown,
Texas. Go Nakamura/Reuters
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One factor slowing down BEST is that the F.D.A. has not yet calculated
what are called background rates, the levels of certain health problems that
normally occur in the non-vaccinated population. These are critical for
determining whether the vaccine is actually causing a spike in certain
problems, such as heart attacks, strokes, and other issues that the F.D.A.
and C.D.C. consider adverse events of special interest, which require close
monitoring.
Rather than calculate them on its own, as the C.D.C. does, the F.D.A. sent a
proposal out for public comment, in which it detailed how it planned to
compute the background rates. They plan to start working on it in the next
few weeks. This delay strikes some public health experts as unnecessary.
“It’s a little bit surprising,” said Dr. Peter Lurie, president of the Center for
Science in the Public Interest, and a former associate commissioner at the
F.D.A. “That doesn’t feel like a mechanism appropriate to the urgency of a
pandemic. It seems to me that a few well-placed phone calls to key people
in the field would provide as much information as a request for comment.”
Dr. Peter Marks, the director of the F.D.A.’s Center for Biologics Evaluation
and Research, which oversees vaccine approval and safety, said the agency
needed outside input.
“The background rates are a critical input for our rapid cycle analysis, so we
followed a deliberative and transparent process,” he said in an interview.
“We needed to develop an approach that could be used in several health
care claims data systems and we needed to account for the possibility that
health care utilization may have changed during the pandemic.”
Jeffrey Brown, an associate professor at Harvard Medical School and a
leader of the F.D.A. program that monitors adverse reactions to drugs, said
he is concerned about the lack of insurance claims data and other holes in
the vaccine safety surveillance systems.
“It is imperative to have policies that ensure vaccination data are submitted
to insurers to enable effective use of the nation’s investment in active safety
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monitoring,” said Dr. Brown. “It is not only critical to get needles into
arms, but also to get data into databases. We still have a chance to get it
done well.”
Denise Grady contributed reporting.
ADVERTISEMENT
Jessica Hill/Associated Press
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From: "Forshee, Richard" >
To: "Forshee, Richard" >
Subject: FW: Summary of DE issue and concerns
Date: Wed, 31 Aug 2022 12:13:26 +0000
Importance: Normal
Sent: Thursday, September 16, 2021 12:33 PM
Subject: RE: Summary of DE issue and concerns
Dear Peter,
Thank you for raising this with CDER we appreciate the help with this. We'll keep you updated on any further
developments with Ana.
Regards,
Steve
Steve Anderson, Ph.D., M.P.P.
Director
Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research
U. S. Food & Drug Administration
Phone:
email:
Sent: Thursday, September 16, 2021 4:54 AM
Subject: FW: Summary of DE issue and concerns
Dear Steve and Rich,
FYI in follow up.
Best Regards,
Peter
Sent: Wednesday, September 15, 2021 8:49 PM
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Subject: FW: Summary of DE issue and concerns
Peter, thanks for flagging this — we’ve made it clear to her that she should not be
discussing or providing internal analyses externally, and needs to focus on her
assigned work. My apologies that this was thrown into the mix at a challenging time
— from Steve’s note, it’s evident that your team is aware of the issues, and planning
on looking into the approach your taking at an appropriate time.
Hopefully, you won’t have further surprises...
Peter
Sent: Wednesday, September 15, 2021 4:55 AM
To: Cavazzoni, Pat! >
Cc: Walinsky, Sarah
Subject: FW: Summary of DE issue and concerns
Dear Patrizia,
| really am sorry to bother you with this, but issue is become a major distraction. One of the CDER statisticians, Ana
Szarfman, has decided on her own to do vaccine analyses using VAERS as part of her work at FDA. She is, however, not
doing this in collaboration with our CBER statisticians, and quite to the contrary, has been asked to cease and desist,
because the strategy that she is using could create erroneous conflicts that feed in to anti-vaccination rhetoric. This is
creating an issue, as documented below by our office director, Steve Anderson.
This issue came up previously during the pandemic and working with Gerald it seemed to go away, but it is now back. Can
we catch up about this sometime?
Thanks,
Peter
Sent: Tuesday, September 14, 2021 10:59 PM
To: Marks, Peter >
Subject: Summary of DE issue and concerns
Dear Peter,
Below is a summary of an issue and concerns expressed by the OBE Division of Epidemiology and IOD:
We are very appreciative of Ana’s extensive knowledge and expertise related to data mining. However, we have concerns
about her communicating data mining findings using CBER VAERS data to CBER and non-CBER personnel. While we think
these efforts are well intentioned, we would request she refrain from using her FDA email or communicating data mining
findings using CBER VAERS data given she is a CDER employee.
As background, when the CBER Division of Epidemiology leadership began planning its approach to passive surveillance for
the COVID-19 vaccines in the summer of 2020, the overarching strategy was to build on existing, established systems
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whenever possible. With regard to Data Mining, DE feels it is important to utilize the standardized, established system
that has been in use for other vaccines for the past several years. The Division is concerned that use of a novel approach
that had not been validated (and to our knowledge, has not been adopted by other medical product centers) would add
another layer of uncertainty in the context of an EUA during the COVID-19 pandemic when rapid retrieval and
interpretation of data would be imperative. DE recognizes as with all passive surveillance our current data mining process
has limitations. In particular, DE is well aware that if there is a class-effect (e.g., if both mRNA COVID-19 vaccines are
associated with the same adverse event) it may be missed by data mining.
DE is planning to re-evaluate the data mining approach (as well as our other processes) once the data from active
surveillance is available. In the best of circumstances data mining is only hypothesis generating and DE believes it would
be helpful once active surveillance has confirmed the hypothesis related to a certain safety signal(s) to re-evaluate our
approach. This would be a suitable time to determine why it wasn’t detected by data mining (if that is the case). This
retrospective approach is more downstream than what Ana is proposing but would be preferable to shifting midstream.
Let us know if you have questions or wish to discuss. Sorry for the hassles with this.
Regards,
Steve
Steve Anderson, Ph.D., M.P.P.
Director
Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research
U.S. Food & Drug Administration
Phone: P|
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From: "Szarfman, Ana" ra
To: "Califf, Robert" ‘Robert Califf, M.D." 5 ti‘i‘s:sCS
Subject: Interesting paper with very similar ideas to our paper
Date: Thu, 4 Aug 2022 01:14:43 +0000
Importance: Normal
Attachments: Perspective Hamburg_et_al_nejmp2207374_(2).pdf
Inline-Images: image001.png
Good Night Dear Dr. Califf,
| wanted to let you know that today, the NEJM published an interesting perspective paper with very similar
ideas to our paper in Nature pj Journal.
Please refer to the attachment and link below:
Building a National Public Health System in the United States | NEJM
https://www.nejm.org/doi/full/10.1056/NEJMp2207374?
Query=TOC&cid=NEIM%20eToc, %20August%204,%202022%20DM1314883 NEJM Non Subscriber&bid=10993
25007
Ana
Sent: Sunday, July 17, 2022 12:13 PM
Subject: Re: New papers FYI
Thanks. These are good.
rmc
Date: Sunday, July 17, 2022 at 8:38 AM
Subject: New papers FYI
Good Morning Dear Dr. Califf,
From the trenches:
Please refer to our first attached paper (currently under an embargo by Nature pj
Communications Medicine) entitled: Recommendations for achieving interoperable and
shareable medical data in the USA, that will be published tomorrow Mon July 18, 2022, and be
available at the following site: https://www.nature.com/articles/s43856-022-00148-x.
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| have previously sent you a draft copy of our recommendations.
Please also note attached another paper recently published describing advances in the data
mining (DM) methodology, especially the capacity to unmask hidden signals due to previously
unaccountable confounders in the denominators available in the following site:
https://rdcu.be/cQhDH.
| think this new data mining technology by Bill DuMouchel can be applied to address
some additional pressing needs besides safety. They include to understand and quickly
address the data quality problems generated by too prevalent mapping and remapping
routines w/o traceability to the factual data.
Warmest regards,
--Ana
Ana Szarfman, MD, PhD, FAMIA, Medical Officer
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical
Informatics (2017), and Fellow of the American Medical Informatics Association (2020)
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food
and Drug Administration
DTN
U.S.
FOOD & DRUG
ADMINISTRATION
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Perspective
The NEW ENGLAND JOURNAL of MEDICINE
August 4, 2022
n engl j med 387;5 nejm.org August 4, 2022 385
O
ver the past 2 years, as 1 million lives have
been lost in the United States, the coronavi-
rus pandemic has laid bare the shortcom-
ings of the country’s haphazard approach to public
health.1 Recent reports on the pan-
demic response have identified
major gaps in leadership, coordi-
nation, communications, testing,
and attention to critical issues of
equity.2,3
These problems are not new;
analyses after the 2001 anthrax
attacks, the 2009 H1N1 influenza
pandemic, and the 2015 Ebola out-
break also identified weaknesses.
Major challenges are not limited to
infectious diseases; the spiraling
epidemic of overdose deaths,
growing burden of diabetes, and
dramatic increases in maternal
mortality, particularly among Black
women, also reflect the inadequa-
cy of the public health enterprise.
According to the World Bank, the
United States ranks below more
than 60 other countries in life ex-
pectancy, with major disparities
according to race, ethnicity, and
geography.
What will it take for the coun-
try to do better? In March 2022,
the Commonwealth Fund con-
vened the nine of us as the Com-
mission on a National Public
Health System to propose urgent,
necessary, and realistic reforms.
Over 90 days, we reviewed reports
and recommendations spanning
the past two decades, consulted
with dozens of stakeholder groups,
experts, and government officials,
and reviewed more than 100 pub-
lic comments.
It was a clarifying process. We
heard time and again that readi-
ness is much more than a plan on
the shelf and countermeasures
in a storage facility. Effective re-
sponses depend on strong routine
public health efforts, grounded in
a core set of capabilities that pro-
tect health and save lives, every
day. Moreover, there was broad
agreement that the United States
can no longer rely on a discoor-
dinated collection of nearly 3000
public health agencies without
consistent standards and account-
ability for health improvement.
Accordingly, in our final re-
port published on June 21, 2022,4
we call for the development of a
national public health system to
promote and protect the health of
all people, regardless of who they
are and where they live; to imple-
ment effective prevention and re-
sponse strategies with partners in
the public and private sectors; and
to earn public trust.
Building a National Public Health System in the United States
Margaret A. Hamburg, M.D., Mandy Cohen, M.D., M.P.H., Karen DeSalvo, M.D., M.P.H.,
Julie Gerberding, M.D., M.P.H., Joneigh Khaldun, M.D., M.P.H., David Lakey, M.D.,
Ellen MacKenzie, Ph.D., Sc.M., Herminia Palacio, M.D., M.P.H., and Nirav R. Shah, M.D., M.P.H.
The New England Journal of Medicine
Downloaded from nejm.org by ANA SZARFMAN on August 3, 2022. For personal use only. No other uses without permission.
Copyright © 2022 Massachusetts Medical Society. All rights reserved.PSI-HHS-000004461924
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PERSPECTIVE
386
Building a National Public Health System
n engl j med 387;5 nejm.org August 4, 2022
Building this national public
health system starts with federal
leadership. The Department of
Health and Human Services (HHS)
is home to multiple agencies
with major roles in public health,
including the Centers for Disease
Control and Prevention, but their
efforts are often insufficiently
coordinated. Moreover, no single
office or person has the dedicat-
ed responsibility for public health.
HHS also lacks the authority to
require collection of information
essential to monitoring threats to
health and has little flexibility to
call upon and move resources ur-
gently.
Addressing these gaps should
be an urgent national priority, and
legislation introduced by Senators
Patty Murray (D-WA) and Richard
Burr (R-NC) is an opportunity to
move forward rapidly (see box).
Among other steps, we argue that
Congress should establish a new
undersecretary or deputy secretary
for public health in HHS. This
empowered role would be a focal
point for accountability and re-
sponsibility, coordinating the re-
sponses of the nation’s health
agencies to major, ongoing pub-
lic health challenges, as well as
leading the long-overdue modern-
ization of public health data and
surveillance systems, workforce,
and laboratories.
Under the U.S. Constitution,
states have the primary responsi-
bility for protecting the health of
the public. At the same time, there
is a strong federal interest in states
doing this job well, especially since
threats in one area easily spread
to others. Thus, Congress should
provide adequate and reliable sup-
port for the health departments of
states, localities, tribes, and ter-
ritories. Upgrading public health
agencies, including their workforce
and information technology,
would cost approximately $8 bil-
lion more annually than current
expenditures, with potential sav-
ings as illnesses are averted and
crises mitigated; the pandemic is
estimated to have cost the U.S.
economy more than $16 trillion.5
As former federal, state, and
local health officials, we recog-
nize that in exchange for this new
funding, there must be standards
and expectations to meet these
standards. HHS should condition
public health infrastructure grants
and flexibility in the use of fed-
eral funds on progress toward
meeting core public health capa-
Immediate Steps to Build a National Public Health System.
For Congress:
• Establish a position of undersecretary or deputy secretary for health to provide leadership and accountability for developing the national
public health system.
• Provide adequate and reliable funding to states, localities, tribes, and territories to support building the core public health capabilities in
all health departments, in exchange for results, certified through accreditation.
• Provide the necessary funding to support a modern public health information technology system and provide the Department of Health
and Human Services and its agencies the necessary authority to establish and enforce standards and implementation for that system.
• Target funding already appropriated ($3.7 billion from the American Rescue Plan Act for fiscal year 2022) for public health workforce devel-
opment and infrastructure as down payments toward building core public health capabilities and modern information systems through-
out the country.
• Direct the Centers for Medicare and Medicaid Services to start regularly mapping and sharing deidentified data to inform communities
about health conditions and identify inequities and to start providing incentives for sharing health care data at the state level.
• Direct efforts to improve and modernize the accreditation for health departments.
• Accelerate efforts to modernize public health communications, including by expanding on the effort led by the Office of the Surgeon
General to counter misinformation and disinformation.
For states, localities, tribes, and territories:
• Examine their health departments’ abilities to meet core public health capabilities and, where health departments are very small, consider
regional service-sharing approaches to providing essential public health protections.
• Create requirements for health care and public health to work together to support achievement of critical public health goals.
• Actively engage community residents in decision making regarding public health priorities.
For health care organizations:
• Jointly conduct community needs assessments with public health agencies and implement needed follow-on activities.
• Implement mechanisms to share data with public health agencies in support of community health improvement.
• Develop opportunities for cross-training and exchanges with public health.
For community organizations:
• Participate in planning activities of health agencies, including by setting key priorities for funding.
• Partner with local health agencies to provide accurate and effective messaging, including that needed to counter misinformation and dis-
information.
• Demand ethical standards, integrity, and transparency from health agencies at all levels.
The New England Journal of Medicine
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Copyright © 2022 Massachusetts Medical Society. All rights reserved.PSI-HHS-000004461925
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 32 of 197 —
PERSPECTIVE
387
Building a National Public Health System
n engl j med 387;5 nejm.org August 4, 2022
bilities, as defined by the Public
Health National Center for Inno-
vations and as certified through
a revised accreditation process that
builds on the work of the Public
Health Accreditation Board. Such
an approach would encourage
states to consider regional service
sharing or consolidating some of
our 2800 local health departments.
Some states, including Indiana
and Missouri, have already begun
to reassess their organization of
public health efforts.
During the pandemic, many
health care delivery systems and
clinicians rallied to support local
public health efforts, sharing
workforce, communications plat-
forms, and data. Such collabora-
tions should not disappear as the
pandemic recedes, only to be rein-
vented for the next crisis. Rather,
they should pivot to day-to-day
health challenges, such as prevent-
ing complications of chronic ill-
ness, addressing urgent mental
health concerns, or identifying
emerging outbreaks of disease.
Integration of the health care sys-
tem in public health efforts will
require both new funding and
heightened accountability tied to
ongoing federal support.
Greater sharing of health care
data with public health agencies
can start today. The Centers for
Medicare and Medicaid Services
can regularly share deidentified
data and maps to inform local
public health efforts. Then, with
new authority from Congress,
HHS can condition new infra-
structure funding on states’ de-
veloping and using near-real-time,
statewide, all-payer databases,
which can support collaborative
efforts such as tracking cases of
childhood asthma. HHS should
also be able to require standard-
ized reporting on hospital resourc-
es and supplies, such as bed and
ICU capacity and availability of
personal protective equipment,
ventilators, and staffing. These ca-
pabilities, which can inform local
efforts every day, are the founda-
tion for robust responses to dis-
asters.
Mobilizing the health care
workforce for public health is
another major opportunity. HHS
can support public health train-
ing for staff in community health
centers and health systems, as
well as opportunities for rotating
through state and local health
departments. With more than 80
million people covered, Medicaid
and the Children’s Health Insur-
ance Program present a special
opportunity for joint action. The
staff of state Medicaid offices and
managed care plans can work
closely with public health agen-
cies, including through contractual
arrangements, to improve health
outcomes.
In our deliberations, we came
to recognize that new structures
and policies — however important
— are limited in what they can
accomplish. To succeed, public
health agencies must earn and
maintain public trust. The pan-
demic has revealed two profound
challenges: long-standing suspi-
cion on the part of many people
who experience racism, discrimi-
nation, and marginalization in
health care and public health, and
strident opposition from those who
rejected evidence-informed restric-
tions that were imposed to reduce
the risk of illness and death.
We recognize that addressing
these gaps requires a long-term
commitment. Public health agen-
cies will have to work closely with
community residents, fund local
organizations, and share deci-
sion making regarding local pri-
orities. This work should involve
collaborations with businesses and
agencies in other sectors to ad-
dress fundamental drivers of poor
health, which communities often
prioritize over traditional public
health activities.
To blunt the corrosive effects of
misinformation and disinforma-
tion, HHS should lead a major
upgrade of public health commu-
nications on multiple platforms
and for multiple audiences. To
help the public understand the
reasons for difficult decisions,
HHS should also develop and im-
plement model standards for eth-
ics, transparency, and integrity.
It will be no small task to pull
the U.S. approach to public health
into the 21st century, but there
are outsized reasons to do so. Es-
tablishing a national public health
system will save lives from ongo-
ing health challenges, protect our
economy during future public
health crises, and respect the
extraordinary sacrifices of pub-
It will be no small task to pull
the U.S. approach to public health
into the 21st century, but there
are outsized reasons to do so.
The New England Journal of Medicine
Downloaded from nejm.org by ANA SZARFMAN on August 3, 2022. For personal use only. No other uses without permission.
Copyright © 2022 Massachusetts Medical Society. All rights reserved.PSI-HHS-000004461926
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— Page 33 of 197 —
PERSPECTIVE
388
Building a National Public Health System
n engl j med 387;5 nejm.org August 4, 2022
lic health and health care work-
ers during the pandemic. If not
now, when?
Disclosure forms provided by the au-
thors are available at NEJM.org.
From the Commonwealth Fund Commis-
sion on a National Public Health System,
New York (M.A.H., M.C., K.D., J.G., J.K.,
D.L., E.M., H.P., N.R.S.); Aledade (M.C.)
and the Foundation for the National Insti-
tutes of Health (J.G.), Bethesda, and Johns
Hopkins Bloomberg School of Public
Health, Baltimore (E.M.) — all in Maryland;
Google, Mountain View (K.D.), and the
Clinical Excellence Research Center, De-
partment of Medicine, Stanford University,
Palo Alto (N.R.S.) — both in California; CVS
Health, Woonsocket, RI (J.K.); the Depart-
ment of Medicine, University of Texas at
Tyler Health Science Center, Tyler (D.L.);
the Guttmacher Institute, Washington, DC
(H.P.); and American Health Associates,
Davie, FL (N.R.S.).
This article was published on June 21, 2022,
at NEJM.org.
1. Wallace M, Sharfstein JM. The patch-
work U.S. public health system. N Engl J
Med 2022;386:1-4.
2. DeSalvo K, Hughes B, Basset M, et al.
Public health COVID-19 impact assessment:
lessons learned and compelling needs.
Washington, DC: National Academy of Med-
icine. April 7, 2021 (https://nam.edu/public
-health-covid-19-impact-assessment-lessons
-learned-and-compelling-needs/).
3. Oladele CR, McKinnsey TL, Tolliver D,
Tuckson R, Dawes D, Nunez-Smith M. The
state of Black America and COVID-19: a two-
year assessment. Black Coalition Against
Covid, 2022. (https://blackcoalitionagainst
covid.org/the-state-of-black-america-and
-covid-19/).
4. Hamburg MA, Cohen M, DeSalvo K, et
al. Meeting America’s public health chal-
lenge: recommendations for building a na-
tional public health system that addresses
ongoing and future health crises, advances
equity, and earns trust. New York: The Com-
monwealth Fund. June 21, 2022 (https://
www.commonwealthfund.org/publications/
fund-reports/2022/jun/meeting-americas
-public-health-challenge).
5. Cutler DM, Summers LH. The COVID-19
pandemic and the $16 trillion virus. JAMA
2020;324:1495-6.
DOI: 10.1056/NEJMp2207374
Copyright © 2022 Massachusetts Medical Society.
A Preview of the Dangerous Future of Abortion Bans —
Texas Senate Bill 8
Whitney Arey, Ph.D., Klaira Lerma, M.P.H., Anitra Beasley, M.D., M.P.H., Lorie Harper, M.D., M.S.C.I.,
Ghazaleh Moayedi, D.O., M.P.H., and Kari White, Ph.D., M.P.H.
W hen the U.S. Supreme Court
issues its decision in Dobbs
v. Jackson Women’s Health Organiza-
tion, the abortion care landscape
will most likely be changed for at
least a generation. Even before a
draft opinion was leaked, many
experts anticipated that the Court
would overturn Roe v. Wade, and
nearly half the states are poised
to ban or dramatically limit abor-
tion care when that occurs.1 These
state laws criminalizing abortion
may allow for very narrow exemp-
tions, and anyone who violates
the law could be subject to civil
penalties, criminal fines, or im-
prisonment.2
Health systems and clinicians
planning their responses3 can look
to Texas, where we have already
witnessed the impact of strict
abortion bans on the provision of
evidence-based, essential health
care for pregnant people. Since
September 1, 2021, Texas Senate
Bill 8 (SB8) has prohibited abor-
tions after the detection of embry-
onic cardiac activity, which occurs
around 6 weeks after a person’s
last menstrual period. After that
point, SB8 allows abortions only
in physician-documented medical
emergencies. Anyone suspected
of violating the law or aiding and
abetting a prohibited abortion can
face a civil lawsuit with monetary
penalties of at least $10,000.
We interviewed 25 clinicians
from across Texas about how SB8
has affected their practice in gen-
eral obstetrics and gynecology,
maternal and fetal medicine
(MFM), or genetic counseling. We
concurrently interviewed 20 Tex-
ans who had medically complex
pregnancies and sought care ei-
ther in Texas or out of state after
September 1, 2021. Although
aimed at clinicians who provide
abortion care, SB8 has had a
chilling effect on a broad range
of health care professionals, ad-
versely affecting patient care and
endangering people’s lives.
Some Texas clinicians still
provide abortion counseling and
referrals, believing that the law
does not limit their free speech,
while also noting that such free-
dom depends on a clinician’s
willingness to assume possible
legal risk. On the basis of legal
guidance, other Texas clinicians
believe they are not even allowed
to counsel patients regarding the
availability of abortion in cases
of increased maternal risks or
poor fetal prognosis, although
before SB8 they would have done
so. Many clinicians have also been
advised that they cannot provide
The New England Journal of Medicine
Downloaded from nejm.org by ANA SZARFMAN on August 3, 2022. For personal use only. No other uses without permission.
Copyright © 2022 Massachusetts Medical Society. All rights reserved.PSI-HHS-000004461927
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From: "Anderson, Steven"
To:
"Marks,
Peter"
>,
"Forshee,
Richard"
Subject: RE: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System
Running
Date: Mon, 01 Mar 2021 20:48:02 -0000
Importance: Normal
Inline-Images: image002.png
Dear Peter,
Sounds good. We will talk then.
Regards,
Steve
Steve Anderson, Ph.D., M.P.P.
Director
Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research
U. S. Food & Drug Administration
Sent: Monday, March 1, 2021 3:45 PM
Subject: RE: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
Dear Steve and Rich,
Thanks for participating. | look forward to catching up at our 2:2 on how to proceed.
Best Regards,
Peter
From: Szarfman, Ana
Sent: Monday, March 1, 2021 2:08 PM
To: Marks, Peter >; Anderson, Steven >; Forshee, Richard
>; Dal Pan, Gerald >; Witten, Celia (CBER)
>; Stockbridge, Norman L >
Subject: RE: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
Hi All,
PSI-HHS-000004584613
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| enjoyed the opportunity to have this discussion with you.
| have attached an updated presentation and the WSJ article on IBM retreating from Watson.
Warmest
regards,
--Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical Informatics (2017), and
Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
Celebrating nearly a quarter of a century of successful implementation of safety data mining, interactive patient profiles,
and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food and Drug Administration
iy
U.S.
FOOD
& DRUG
ADMINISTRATION
-----Original Appointment--
From: Marks, Peter
<j
>
Sent: Wednesday, February 17, 2021 6:50 PM
To: Marks, Peter; Anderson, Steven; Forshee, Richard; Szarfman, Ana; Dal Pan, Gerald; Ball, Robert; Witten, Celia (CBER);
Stockbridge, Norman
L
Subject: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
When: Monday, March 1, 2021 1:00 PM-2:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: WebEX
Importance: High
From: Szarfman, Ana
Sent: Sunday, February 14, 2021 9:31 AM
To: Marks, Peter >
Ce: Stockbridge, Norman L >
Subject: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
Hi Peter.
Thanks so much for your work.
Regarding the NYT article, | am quite concerned that the distributed network of EHRs that the
Sentinel System uses does not have mortality data, and that they (and we) are not clamoring to
fix this problem. It still takes several years to collect mortality data. Indeed there are no
incentives to update electronic health records with mortality data.
PSI-HHS-000004584614
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https://www.nytimes.com/2021/02/12/health/covid-vaccine-how-safe.html?
referringSource=articleShare
> Let me know if you want Bill DuMouchel and | to discuss our proposal for more effective
monitoring, including the need to use an updated algorithm by DuMouchel for data mining
spontaneous reports at CDER and CBER.
Many thanks,
--Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical
Informatics (2017), and Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
Celebrating nearly a quarter of a century of successful implementation of safety data mining,
interactive patient profiles, and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food
and Drug Administration
When it's time, join your Webex meeting here.
More ways to join:
Join from the meeting link
Join by meeting number
Tap to join from a mobile device (attendees only)
US Toll
US Toll Free
Join by phone
PSI-HHS-000004584615
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 37 of 197 —
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
a: Toll
US Toll Free
lobal call-in numbers | Toll-free calling restrictions
If you are a host, click here to view host information.
Need help? Go to https://help.webex.com
PSI-HHS-000004584616
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AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
From: "Niu, Manette" >
To: "Anderson, Steven' ba
Subject: RE: OBE Activities
Date: Wed, 18 Nov 2020 19:01:31 +0000
Importance: Normal
lam also working with Diane Gubernot on the Background rate project manuscript (in collaboration with CDC) — this has a
quick timeline with the due date for a draft manuscript being mid-Dec. 2020.
| have a meeting with Ana Szarfman tomorrow to discuss her proposal on instituting new methods to improve data
mining.
Thank you!
Manette
From: Niu, Manette
Sent: Wednesday, November 18, 2020 1:58 PM
Subject: OBE Activi
Steve,
| wanted to check in with you now that I’m back from filling in for AEB.
Please let me know if there is anything else you would like me to attend to besides the BEST and surveillance meetings |
am currently on? | thought it would be informative if | continue to attend/follow DE COVID-19 surveillance
meetings/activities, including those in which DE collaborates with CDC.
Thank you!
Manette
PSI-HHS-000004585100
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From: "Forshee, Richard"
To: "Marks, Peter"
Cc: "Anderson, Steven"
>,
"Witten,
Celia
(CBER)"
Subject: Contact from Ana Szarfman
Date: Tue, 13 Jul 2021 17:55:16 +0000
Importance: Normal
Embedded: Issue__1_--_Death_signal_-->_WVAERS_2021W21_data_loaded_on_slc06lhx
Inline-Images: image001.png; image002 jpg; image003.jpg; image004.jpg:; image005.jpg; image006.jpg
Dear Peter,
Ana Szarfman called me at about 4:15pm on Friday 7/9. She said that she and Bill DuMouchel had found an increased risk
of mortality following COVID-19 vaccination using data mining methods. | asked her to send me the analysis and promised
to review it, and I’ve attached the email she sent on Monday 7/12. It has very little information on the methods. I’ve
pasted my reply to her below.
lam very concerned that whatever association they think they have identified is spurious based on the way the COVID-19
vaccination program prioritized individuals and the required and stimulated reporting we are seeing with the COVID-19
vaccines. Ana said that she had taken her name off a publication that is being prepared.
Please let me know how you would like us to proceed.
Best Regards,
-Rich
‘Response to An:
Hi Ana,
Thanks for sharing this, and my team will review it. Do you have any more details on the new methods that Bill
DuMouchel is using? That would be helpful in our evaluation.
In the email thread, Bill asked, “Can anyone propose theories of what potential biases are causing them to have
such high disproportionalities? We hoped that use of AgeGroup11 would eliminate the main bias.”
During the time frame of this analysis, people with high-risk medical risk conditions were prioritized for
vaccination. This included people in Nursing Homes early in the rollout. In later phases, most people needed to
demonstrate that they had a high-risk medical condition to qualify for a vaccination. These included conditions
like diabetes, chronic lung diseases, hypertension, heart conditions, obesity, and liver disease. Unless Bill has
controlled for this somehow, | worry that the disproportionality in these results is caused by selection bias.
What are your thoughts on this possibility?
Best regards,
--Rich
End of Respons:
PSI-HHS-000004588545
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AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
Richard Forshee, Ph.D.
Acting Deputy Office Director, CBER/OBE
Center for Biologics Evaluation and Research
Office of Biostatistics and Epidemiology
Analytics and Benefit-Risk Assessment Team
U.S. Food and Drug Administration
PN
U.S.
FOOD
& DRUG
ADMINISTRATION
BoOooO- 8
PSI-HHS-000004588546
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From: "Szarfman, Ana"
To: "Forshee, Richard"
Ce: "Stockbridge, Norman L" >, "Weichold, Frank"
Subject: Issue #1 -- Death signal --> WVAERS 2021W21 data loaded on slc06lhx
Date: Mon, 12 Jul 2021 20:36:06 +0000
Importance: Normal
Attachments: VaccineHLT.xlsx
Inline-Images: image003.png
Hi Dear Richard,
Many thanks for all the extremely important work you are all doing!
As we talked over the phone, | became aware last Fri that scientists from Cornell are concerned of an increased mortality
signal with the COVID-19 vaccines.
We detected such a signal using the data collected by VAERS during the week ending on May 30, 2021, and made public
one or
two
weeks later.
Please refer to the attached spreadsheet and to the email from Bill DuMouchel that | am forwarding, dated June 20, 2021.
Note that Bill used RGPS, a method that automatically unmask signals that remain hidden by other data mining
methodologies, including by MGPS (a method we implemented in 1998).
For the COVID-19 analyses, Bill does not stratify by year, since in 2021 over 95% of the VAERS reports are for COVID-19
vaccines, and we would not have a proper background from all other vaccines to make comparisons.
Let me know if you have any questions.
Many thanks,
--Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical Informatics (2017), and
Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
Celebrating nearly a quarter of a century of successful implementation of safety data mining, interactive patient profiles,
and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food and Drug Administration
TN
U.S. FOOD & DRUG
ADMINISTRATION
PSI-HHS-000004592364
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
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From: Bill DuMouche! <i>
Date: June 20, 2021 at 22:46:05 EDT
Subject: Re: WVAERS 2021W21 data loaded on slcO06Ihx
I created two runs based on Week21 VAERS:
ID 412: Vaccine Type vs PT
1D413: Vaccine+Manufacturer vs HLT
I'm attaching an Excel file with results from run 413. Sheet 1 has 24 masked DECs and Sheet 2 has all DECs.
Masking is here defined as ERO5 >EB95 and EROS5>1 and ERAM > 1.5*EBGM
It seems to me that whena strong signal shows up at the HLT level, it should be hard to discount it.
For sheet 1, note signals for the two HLTs Death and sudden death and Non-site specific embolism and
thrombosis show up for all three COVID19 vaccines.
Are we just supposed to ignore over 4000 of the former and 1500 of the latter HLT reports?
Can anyone propose theories of what potential biases are causing them to have such high
disproportionalities? We hoped that use of AgeGroup11 would eliminate the main bias.
Bill
Sent: Thursday, June 17, 2021 9:34 AM
To: BillDuMouchel >; Steve Bright <i
>
Subject: WVAERS 2021W21 data loaded on slcO6lhx
Rave Harpaz
Hi Bill, Steve, Rave,
WVAERS 2021W21 data has been loaded to slcO06lhx server.
Ruixia
PSI-HHS-000004592365
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From: "Forshee, Richard"
To: "Marks, Peter"
Cc: "Anderson, Steven"
Subject: FYI: Ana Szarfman publication on COVID-19 vaccine safety
Date: Wed, 31 Aug 2022 12:28:10 +0000
Importance: Normal
Embedded: FW:_Summary_of DE _issue_and_concems
Inline-Images: image001.png; image002 jpg; image003.jpg; image004.jpg; image005 jpg; image006.jpg
Dear Peter,
| believe you will recall our conversations about the work that Ana Szarfman (CDER) was doing on COVID-19 vaccine
safety. | have attached a copy of an email from about a year ago where you shared our concerns with CDER.
We have just learned that Dr. Szarfman is a co-author on a recently published paper based on COVID-19 vaccines and
VAERS. We believe there are a number of issues with the paper and its findings, and we are discussing how best to
respond. | don’t recall receiving any prior notification from CDER about this publication.
Here is a link to the paper:
ringer.com/article/10.1007/s40264-022-01186-z
We can discuss this at our next scheduled meeting, or we can schedule an ad hoc meeting this week. Please let us know if
you have any other instructions.
Best Regards,
--Rich
Richard Forshee, Ph.D. (he/him/his)
Deputy Director, CBER/OBPV
Center for Biologics Evaluation and Research
Office of Biostatistics and Pharmacovigilance
Analytics and Benefit-Risk Assessment Team
U.S. Food and Drug Administration
iPZN
U.S.
FOOD
& DRUG
ADMINISTRATION
PSI-HHS-000004594929
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From: "Marks, Peter"
To: "Anderson, Steven" >, "Forshee, Richard"
Subject: FW: Summary of DE issue and concerns
Date: Thu, 16 Sep 2021 08:53:34 +0000
Importance: Normal
Dear Steve and Rich,
FYI in follow up.
Best Regards,
Peter
Sent: Wednesday, September 15, 2021 8:49 PM
To: Marks, Peter >
Cc: Cavazzoni, Patrizia >
Subject: FW: Summary of DE issue and concerns
Peter, thanks for flagging this — we’ve made it clear to her that she should not be
discussing or providing internal analyses externally, and needs to focus on her
assigned work. My apologies that this was thrown into the mix at a challenging time
— from Steve’s note, it’s evident that your team is aware of the issues, and planning
on looking into the approach your taking at an appropriate time.
Hopefully, you won’t have further surprises...
Peter
From: Marks, Peter -ti‘“‘i;C;SC*&r
Sent: Wednesday, September 1!
To: Cavazzoni, Pat!
Cc: Walinsky, Sarah >
Subject: FW: Summary of DE issue and concerns
Dear Patrizia,
| really am sorry to bother you with this, but issue is become a major distraction. One of the CDER statisticians, Ana
Szarfman, has decided on her own to do vaccine analyses using VAERS as part of her work at FDA. She is, however, not
doing this in collaboration with our CBER statisticians, and quite to the contrary, has been asked to cease and desist,
because the strategy that she is using could create erroneous conflicts that feed in to anti-vaccination rhetoric. This is
creating an issue, as documented below by our office director, Steve Anderson.
This issue came up previously during the pandemic and working with Gerald it seemed to go away, but it is now back. Can
we catch up about this sometime?
PSI-HHS-000004604858
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Thanks,
Peter
Sent: Tuesday, September 14, 2021 10:59 PM
To: Marks, Peter >
Cc: Forshee, Richard
Subject: Summary of DE issue and concerns
Dear Peter,
Below is a summary of an issue and concerns expressed by the OBE Division of Epidemiology and IOD:
We are very appreciative of Ana’s extensive knowledge and expertise related to data mining. However, we have concerns
about her communicating data mining findings using CBER VAERS data to CBER and non-CBER personnel. While we think
these efforts are well intentioned, we would request she refrain from using her FDA email or communicating data mining
findings using CBER VAERS data given she is a CDER employee.
As background, when the CBER Division of Epidemiology leadership began planning its approach to passive surveillance for
the COVID-19 vaccines in the summer of 2020, the overarching strategy was to build on existing, established systems
whenever possible. With regard to Data Mining, DE feels it is important to utilize the standardized, established system
that has been in use for other vaccines for the past several years. The Division is concerned that use of a novel approach
that had not been validated (and to our knowledge, has not been adopted by other medical product centers) would add
another layer of uncertainty in the context of an EUA during the COVID-19 pandemic when rapid retrieval and
interpretation of data would be imperative. DE recognizes as with all passive surveillance our current data mining process
has limitations. In particular, DE is well aware that if there is a class-effect (e.g., if both mRNA COVID-19 vaccines are
associated with the same adverse event) it may be missed by data mining.
DE is planning to re-evaluate the data mining approach (as well as our other processes) once the data from active
surveillance is available. In the best of circumstances data mining is only hypothesis generating and DE believes it would
be helpful once active surveillance has confirmed the hypothesis related to a certain safety signal(s) to re-evaluate our
approach. This would be a suitable time to determine why it wasn’t detected by data mining (if that is the case). This
retrospective approach is more downstream than what Ana is proposing but would be preferable to shifting midstream.
Let us know if you have questions or wish to discuss. Sorry for the hassles with this.
Regards,
Steve
Steve Anderson, Ph.D., M.P.P.
Director
Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research
PSI-HHS-000004604859
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From:
To:
"Dal Pan, Gerald"
>,
"Stockbridge, Norman
L"
Subject: Follow up from today's meeting on mortality data and data mining
Date: Tue, 2 Mar 2021 02:27:08 +0000
Importance: Normal
Attachments: Trinidad_et_al_-_National_Vital_Statistics_Reports_-_2016.pdf; Hedegaard_et_al_-
_National_Vital_Statistics_Report_-_2018.pdf; FAERS_Reports.xlsx
Inline-Images: image002.png
Peter and others,
Thank you for inviting me to participate in today’s meeting. | have two follow-up items:
1. | mentioned that OSE collaborated with NCHS to examine literal texts from death certificates. | have attached two
papers that describe how this was done (Trinidad et al) and some results (Hedegaard et al).
2. Ana mentioned that adverse event reports for AstrZeneca SARS-CoV-2 vaccine are in FAERS and not VAERS. Our
team worked with Craig Zinderman in OBE to understand this. Since the AstraZeneca vaccine is neither authorized
nor approved, the company as no postmarketing adverse event reporting requirements. The 200+ reports that we
have in FAERS (Excel spreadsheet) list the AstraZeneca vaccine as a ’suspect” drug but not as the “primary suspect”
drug. Nearly all of these reports came from companies other than AstraZeneca, since those are companies were
submitting adverse event reports for their dugs that are approved in the US. It is not unusual for reports for a drug
to appear in FAERS before their US approval date for this reason.
This is all FYI only.
Please let me know if you have any questions.
Thanks.
Gerald
Sent: Monday, March 1, 2021 3:44 PM
To: Szarfman, Ana >; Anderson, Steven >; Forshee, Richard
>; Dal Pan, Gerald >; Witten, Celia (CBER)
>; Stockbridge, Norman L
Subject: RE: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
Dear Ana,
Thanks so much for taking the time to go over everything so carefully with us. We will work through the issues that you
presented.
Best Regards,
Peter
PSI-HHS-000004783470
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From: Szarfman, Ana -tt—“i—sSSSC‘*@
Sent: Monday, March 1, 2021 2:08 PM
To: Marks, Peter
>;
Forshee, Richard
>;
Witten,
Celia
(CBER)
>;
Anderson, Steven
>;
Dal
Pan,
Gerald
>; Stockbridge, Norman L
Subject: RE: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
Hi All,
| enjoyed the opportunity to have this discussion with you.
| have attached an updated presentation and the WSJ article on IBM retreating from Watson.
Warmest
regards,
--Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical Informatics (2017), and
Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
Celebrating nearly a quarter of a century of successful implementation of safety data mining, interactive patient profiles,
and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food and Drug Administration
ADMINISTRATION
U.S. FOOD & DRUG
-----Original Appointment-----
From: Marks, Peter
<j
>
Sent: Wednesday, February 17, 2021 6:50 PM
To: Marks, Peter; Anderson, Steven; Forshee, Richard; Szarfman, Ana; Dal Pan, Gerald; Ball, Robert; Witten, Celia (CBER);
Stockbridge, Norman
L
Subject: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
When: Monday, March 1, 2021 1:00 PM-2:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: WebEX
Importance: High
Sent: Sunday, February 14, 2021 9:31 AM
To: Marks, Peter >
Ce: Stockbridge, Norman L >
Subject: NYT - As Millions Get Shots, F.D.A. Struggles to Get Safety Monitoring System Running
Hi Peter.
Thanks so much for your work.
PSI-HHS-000004783471
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Regarding the NYT article, | am quite concerned that the distributed network of EHRs that the
Sentinel System uses does not have mortality data, and that they (and we) are not clamoring to
fix this problem. It still takes several years to collect mortality data. Indeed there are no
incentives to update electronic health records with mortality data.
https://www.nytimes.com/2021/02/12/health/covid-vaccine-how-safe.html?
referringSource=articleShare
> Let me know if you want Bill DuMouchel and | to discuss our proposal for more effective
monitoring, including the need to use an updated algorithm by DuMouchel for data mining
spontaneous reports at CDER and CBER.
Many thanks,
--Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical
Informatics (2017), and Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
Celebrating nearly a quarter of a century of successful implementation of safety data mining,
interactive patient profiles, and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food
and Drug Administration
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National Vital
Statistics Reports
Volume 65, Number 9
Need
December 20, 2016
Using Literal Text From the Death Certificate to
Enhance Mortality Statistics: Characterizing Drug
Involvement in Deaths
by James P. Trinidad, M.P.H., M.S., U.S. Food and Drug Administration; Margaret Warner, Ph.D., Brigham A.
Bastian, B.S., Arialdi M. Minifio, M.P.H., and Holly Hedegaard, M.D., M.S.PH., National Center for Health Statistics
Abstract
Objectives—This report describes the development and use
of a method for analyzing the literal text from death certificates
to enhance national mortality statistics on drug-involved deaths.
Drug-involved deaths include drug overdose deaths as well as
other deaths where, according to death certificate literal text,
drugs were associated with or contributed to the death.
Methods—The method uses final National Vital Statistics
System-Mortality files linked to electronic files containing literal
text information from death certificates. Software programs were
designed to search the literal text from three fields of the death
certificate (the cause of death from Part |, significant conditions
contributing to the death from Part II, and a description of how
the injury occurred from Box 43) to identify drug mentions as
well as contextual information. The list of drug search terms was
developed from existing drug classification systems as well as
from manual review of the literal text. Literal text surrounding
the identified drug search terms was analyzed to ascertain the
context. Drugs mentioned in the death certificate literal text were
assumed to be involved in the death unless contextual information
suggested otherwise (eg., “METHICILLIN RESISTANT
STAPHYLOCOCCUS AUREUS INFECTION”). The literal text
analysis method was assessed by comparing the results from
application of the method with results based on ICD—-10 codes,
and by conducting a manual review of a sample of records.
Keywords: text analysis ¢ drug-involved death « drug overdose *
National Vital Statistics System
Introduction
Recent mortality trends in the United States show a
substantial increase in the rate of drug overdose deaths. From
2000 to 2014, the mortality rate for drug overdose more than
doubled from 6.2 to 14.7 per 100,000 population (1). To address
this public health concern, many researchers use National Vital
Statistics System mortality data (NVSS-M) to describe these
trends and to monitor the populations most at risk (1-4).
The NVSS-M data are based on information from the death
certificates filed in the 50 states and the District of Columbia.
The data set includes cause-of-death, demographic, and
geographic information extracted from death certificates for all
decedents in the United States (5). The NVSS—M data are coded
using a standardized classification system, the /nternational
Classification of Diseases and Related Health Problems, Tenth
Revision (\CD-10) (6). While this classification system allows
for consistency in identifying the underlying and contributory
causes of death, there are limitations in the use of ICD-10-coded
data to study drug-involved mortality. Specifically, in the ICD-10
classification system, only a few drugs (e.g., heroin, methadone,
and cocaine) are assigned a unique classification code (140.1,
740.3, and 140.5, respectively) under certain circumstances
(e.g., when the death is an overdose). Most drugs, however,
are assigned to broad categories (e.g., both oxycodone and
morphine are categorized to 140.2, Poisoning: Other opioids)
(7). The use of broad categories in ICD-10 makes it difficult to
use ICD-10 coded data to monitor trends in deaths involving
specific drugs that are not already uniquely classified in ICD-10.
Analysis of literal text has been used to enhance mortality
statistics in investigations of sudden infant death syndrome,
Creutzfeldt-Jakob disease, influenza and pneumonia, cancer, and
drug poisonings (8-13). The literal text often includes information
beyond the general classification captured in an ICD-10 code
description. For example, researchers have examined the literal
oo ty
JSC
LE
ng
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Disease Control and Prevention
National Center for Health Statistics
National Vital Statistics System
PSI-HHS-00000481 4097
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2 National Vital Statistics Reports, Vol. 65, No. 9, December 20, 2016
text to better understand the circumstances (e.g., unsafe sleep
environments) contributing to sudden infant death syndrome
(9,12). Literal text can also be analyzed to identify a specific subset
of deaths coded to a broad ICD–10 classification. For example,
reseachers have examined the literal text to identify deaths from
Creutzfeldt-Jakob disease among decedents with an ICD–10
underlying cause of death of B94.8, Sequelae of other specified
infectious diseases (13). Similarly, researchers have explored
literal text analysis methods to better understand the contribution
of specific drugs in drug-poisoning deaths, and found that the
literal text data provided more information on specific drugs than
the ICD–10-coded data (11). These previous literal text analyses
involving information on specific drugs did not consider literal
text information other than drug mentions, were limited by causes
of death, and assessed only records from a single state. Further
development and use of literal text analysis methodology provides
an opportunity for an enhanced understanding of the national
picture of drug involvement in deaths in the United States (11).
This report describes the collaborative efforts of the National
Center for Health Statistics (NCHS) and the U.S. Food and Drug
Administration (FDA) to develop and assess a method for using
literal text from death certificates to identify specific drugs
involved in deaths, that is, drug overdose deaths and deaths
with other types of drug involvement. This report accompanies a
study that highlights the specific drugs most frequently involved
in drug overdose deaths from 2010 through 2014 (14).
Methods Development
Overview
The analysis method uses search terms to identify drugs
mentioned in electronic death certificate literal text (i.e., the
cause-of-death statements on the death certificate). Unless
contextual information suggested otherwise, drugs mentioned
in the death certificate literal text were assumed to be involved
in the death. Therefore, the method also analyzes literal text
surrounding the identified search terms to determine whether the
drugs mentioned were not involved in death (e.g., “METHICILLIN
RESISTANT STAPHYLOCOCCUS AUREUS INFECTION”). The
processed data resulting from applying the method includes all
identified drug mentions and contextual information on drug
involvement.
The following sections describe the data source for the literal
text analysis methodology; some issues considered during the
methods development; an assessment of the quality of the literal
text data; the approach used to optimize the efficiency of literal
text analysis; the development of lists of terms and phrases that
were used in the processing of literal text; the steps of the literal
text analysis methodology; and the data produced by applying
the literal text analysis methodology.
Data source
The literal text analysis methodology was developed using
final NVSS–M data linked to literal text data. Both NVSS–M
data and literal text data are derived from information on death
certificates (5).
In NVSS–M, the coded causes of death are assigned
based on information written in the cause-of-death section on
the death certificate (Figure 1). The information written on the
death certificate by the medical certifier on the cause, manner,
circumstances, and other factors contributing to the death is
referred to as the literal text fields. The literal text fields of the
cause-of-death section on the U.S. Standard Certificate of Death
(15,16) include:
• The chain of events leading to death (from Part I)
• Other significant conditions that contributed to the death
(from Part II)
• How the injury occurred (in the case of deaths due to injuries
[from Box 43])
NCHS uses a software program to code the literal text from
the death certificate according to the rules of ICD–10 (17). These
processes involve the identification of statements from death
certificate literal text, such as “MYOCARDIAL INFARCTION”
and “DIABETES MELLITUS.” Some statements, such as
“METHADONE INTOXICATION,” refer to drug-involved mortality.
The identified statements are translated into ICD–10 codes. For
example, the identified statement “OXYCODONE POISONING”
is coded to ICD–10 codes T40.2, Poisoning: other opioids, and
X42, Accidental poisoning by and exposure to narcotics and
psychodysleptics (hallucinogens), not elsewhere classified.
Note that throughout this report, text from death certificates is
indicated in quotes and uppercase letters.
ICD–10 codes reflect the conditions reported on the death
certificate. During the coding process, the software program
assigns ICD–10 codes to 1 underlying cause and up to 20 multiple
causes of death. Records rejected by the software program are
reviewed by trained nosologists, and ICD–10 codes are manually
assigned. In general, nosologists manually code about one-fifth
of the death records. For deaths with an underlying cause of
drug overdose (deaths with an underlying cause code of X40–
X44, X60–X64, X85, or Y10–Y14), about two-thirds are coded
manually (18). Entity axis ICD–10 codes include the ICD–10
code and information on the placement of the coded condition
on the death certificate.
NCHS maintains the coded NVSS–M final mortality file and
the literal text data separately, and linkage between the NVSS–M
and literal text data leverages the information from both data sets.
To link the data, NVSS–M and literal text files were merged on
year of death, state of occurrence, and death certificate number.
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National Vital Statistics Reports, Vol. 65, No. 9, December 20, 2016 3
Figure 1. U.S. standard death certificate
U.S. STANDARD CERTIFICATE OF DEATH
LOCAL FILE NO. ST ATE FILE NO.
1. DECEDENT’S LEGAL NAME (Include AKA’s if any) (First, Middle, Last) 2. SEX 3. SOCIAL SECURITY NUMBER
4b. UNDER 1 YEAR 4c. UNDER 1 DAY 4a. AGE Last Birthday
(Years) Months Days Hours Minutes
5. DATE OF BIRTH (Mo/Day/Yr) 6. BIRTHPLACE (City and State or Foreign Country)
7a. RESIDENCE STATE 7b. COUNTY 7c. CITY OR TOWN
7d. STREET AND NUMBER 7e. APT. NO. 7f. ZIP CODE 7g. INSIDE CITY LIMITS? □ Yes □ No
8. EVER IN US ARMED FORCES?
□ Yes □ No
9. MARITAL STATUS AT TIME OF DEATH
□ Married □ Married, but separated □ Widowed
□ Divorced □ Never Married □ Unknown
10. SURVIVING SPOUSE’S NAME (If wife, give name prior to first marriage)
11. FATHER’S NAME (First, Middle, Last) 12. MOTHER’S NAME PRIOR TO FIRST MARRIAGE (First, Middle, Last)
13a. INFORMANT’S NAME 13b. RELATIONSHIP TO DECEDENT 13c. MAILING ADDRESS (Street and Number, City, State, Zip Code)
14. PLACE OF DEATH (Check only one: see instructions)
IF DEATH OCCURRED IN A HOSPITAL:
□ Inpatient □ Emergency Room/Outpatient □ Dead on Arrival
IF DEATH OCCURRED SOMEWHERE OTHER THAN A HOSPITAL:
□ Hospice facility □ Nursing home/Long term care facility □ Decedent’s home □ Other (Specify):
15. FACILITY NAME (If not institution, give street & number) 16. CITY OR TOWN , STATE, AND ZIP CODE 17. COUNTY OF DEATH
18. METHOD OF DISPOSITION: □ Burial □ Cremation
□ Donation □ Entombment □ Removal from State
□ Other (Specify):
19. PLACE OF DISPOSITION (Name of cemetery, crematory, other place)
20. LOCATION CITY, TOWN, AND STATE 21. NAME AND COMPLETE ADDRESS OF FUNERAL FACILITY
NAME OF DECEDENT ____________________________________________
For use by physician or institution
To Be Completed/ Verified By:
FUNERAL DIRECTOR:
22. SIGNATURE OF FUNERAL SERVICE LICENSEE OR OTHER AGENT 23. LICENSE NUMBER (Of Licensee)
ITEMS 24-28 MUST BE COMPLETED BY PERSON
WHO PRONOUNCES OR CERTIFIES DEATH
24. DATE PRONOUNCED DEAD (Mo/Day/Yr) 25. TIME PRONOUNCED DEAD
26. SIGNATURE OF PERSON PRONOUNCING DEATH (Only when applicable) 27. LICENSE NUMBER 28. DATE SIGNED (Mo/Day/Yr)
29. ACTUAL OR PRESUMED DATE OF DEATH
(Mo/Day/Yr) (Spell Month)
30. ACTUAL OR PRESUMED TIME OF DEATH 31. WAS MEDICAL EXAMINER OR
CORONER CONTACTED? □ Yes □ No
CAUSE OF DEATH (See instructions and examples)
32. PART I. Enter the chain of events diseases, injuries, or complications that directly caused the death. DO NOT enter terminal events such as cardiac
arrest, respiratory arrest, or ventricular fibrillation without showing the etiology. DO NOT ABBREVIATE. Enter only one cause on a line. Add additional
lines if necessary.
IMMEDIATE CAUSE (Final
disease or condition ---------> a._____________________________________________________________________________________________________________
resulting in death) Due to (or as a consequence of):
Sequentially list conditions, b.____________________________________________________________________________________ _________________________
if any, leading to the cause Due to (or as a consequence of):
listed on line a. Enter the
UNDERLYING CAUSE c._____________________________________________________________________________________________________________
(disease or injury that Due to (or as a consequence of):
initiated the events resulting
in death) LAST d._____________________________________________________________________________________________________________
Approximate
interval:
Onset to death
_____________
_____________
_____________
_____________
33. WAS AN AUTOPSY PERFORMED?
□ Yes □ No
PART II. Enter other significant conditions contributing to death but not resulting in the underlying cause given in PART I
34. WERE AUTOPSY FINDINGS AVAILABLE TO
COMPLETE THE CAUSE OF DEATH? □ Yes □ No
35. DID TOBACCO USE CONTRIBUTE
TO DEATH?
□ Yes □ Probably
□ No □ Unknown
36. IF FEMALE:
□ Not pregnant within past year
□ Pregnant at time of death
□ Not pregnant, but pregnant within 42 days of death
□ Not pregnant, but pregnant 43 days to 1 year before death
□ Unknown if pregnant within the past year
37. MANNER OF DEATH
□ Natural □ Homicide
□ Accident □ Pending Investigation
□ Suicide □ Could not be determined
38. DATE OF INJURY
(Mo/Day/Yr) (Spell Month)
39. TIME OF INJURY 40. PLACE OF INJURY (e.g., Decedent’s home; construction site; restaurant; wooded area) 41. INJURY AT WORK?
□ Yes □ No
42. LOCATION OF INJURY: State: City or Town:
Street & Number: Apartment No.: Zip Code:
43. DESCRIBE HOW INJURY OCCURRED: 44. IF TRANSPORTATION INJURY, SPECIFY:
□ Driver/Operator
□ Passenger
□ Pedestrian
□ Other (Specify)
45. CERTIFIER (Check only one):
□ Certifying physician To the best of my knowledge, death occurred due to the cause(s) and manner stated.
□ Pronouncing & Certifying physician To the best of my knowledge, death occurred at the time, date, and place, and due to the cause(s) and manner stated.
□ Medical Examiner/Coroner On the basis of examination, and/or investigation, in my opinion, death occurred at the time, date, a nd place, and due to the cause(s) and manner stated.
Signature of certifier:_____________________________________________________________________________
46. NAME, ADDRESS, AND ZIP CODE OF PERSON COMPLETING CAUSE OF DEATH (Item 32)
To Be Comp
leted By:
MEDICAL CERTIFIER
47. TITLE OF CERTIFIER 48. LICENSE NUMBER 49. DATE CERTIFIED (Mo/Day/Yr) 50. FOR REGISTRAR ONLY DATE FILED (Mo/Day/Yr)
51. DECEDENT’S EDUCATION Check the box
that best describes the highest degree or level of
school completed at the time of death.
□ 8th grade or less
□ 9th 12th grade; no diploma
□ High school graduate or GED completed
□ Some college credit, but no degree
□ Associate degree (e.g., AA, AS)
□ Bachelor’s degree (e.g., BA, AB, BS)
□ Master’s degree (e.g., MA, MS, MEng,
MEd, MSW, MBA)
□ Doctorate (e.g., PhD, EdD) or
Professional degree (e.g., MD, DDS,
DVM, LLB, JD)
52. DECEDENT OF HISPANIC ORIGIN? Check the box
that best describes whether the decedent is
Spanish/Hispanic/Latino. Check the “No” box if
decedent is not Spanish/Hispanic/Latino.
□ No, not Spanish/Hispanic/Latino
□ Yes, Mexican, Mexican American, Chicano
□ Yes, Puerto Rican
□ Yes, Cuban
□ Yes, other Spanish/Hispanic/Latino
(Specify) __________________________
53. DECEDENT’S RACE (Check one or more races to indicate what the
decedent considered himself or herself to be)
□ White
□ Black or African American
□ American Indian or Alaska Native
□ Asian Indian
(Name of the enrolled or principal tribe) _______________
□ Chinese
□ Filipino
□ Japanese
□ Korean
□ Vietnamese
□ Other Asian (Specify)__________________________________________
□ Native Hawaiian
□ Guamanian or Chamorro
□ Samoan
□ Other Pacific Islander (Specify)_________________________________
□ Other (Specify)___________________________________________
54. DECEDENT’S USUAL OCCUPATION (Indicate type of work done during most of working life. DO NOT USE RETIRED).
To Be Completed By:
FUNERAL DIRECTOR
55. KIND OF BUSINESS/INDUSTRY
REV. 11/2003
SOURCE: NCHS, National Vital Statistics System.
PSI-HHS-000004814099
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4 National Vital Statistics Reports, Vol. 65, No. 9, December 20, 2016
Considerations in developing methods to
process death certificate literal text
In developing the analysis methodology, several
characteristics and limitations of the literal text needed to be
considered.
Availability of literal text information–Deaths may have no
literal text data or only literal text mentions regarding the status of
the death investigation (e.g., mentions of “PENDING” or “UNDER
INVESTIGATION”). For these deaths, there are no mentions of
drugs in the literal text.
Syntax of literal text–The syntax of the death certificate
literal text generally consists of a few words or simple phrases
(e.g., “DRUG TOXICITY”) rather than clauses or sentences
(e.g., “DECEDENT DIED OF DRUG POISONING”). The literal
text analysis methods were developed by imitating the software
program and processes that extract and assign ICD–10 codes to
the literal text information as described above. These processes
identify statements in the text.
Four text fields in Part I–The text fields constituting Part I of
the death certificate have an assumed interpretation: The cause
of death listed in the first text field is due to (or a consequence
of) the cause of death (if any) listed in the second text field,
which is due to (or a consequence of) the cause of death (if any)
listed in the third text field, which is due to (or a consequence of)
the cause of death (if any) listed in the fourth text field. The first
cause of death listed in this sequence is the immediate cause
of death, and the cause of death on the lowest-used line in Part
I is the underlying cause of death. The assumed interpretation
works well for some deaths. However, the assumption does not
work well for other deaths. For example, medical certifiers may
list multiple causes of death on a single line, may list a single
cause of death on multiple lines, or may not write the causes
in the appropriate sequential order. To simplify analyses, the
assumed interpretation in Part I was ignored, and the text fields
constituting Part I were concatenated as a single text field.
Case, symbols, and numbers–Use of uppercase and
lowercase characters, symbols, and numbers varies across
deaths. Some death certificate literal text may be in uppercase
only, others in lowercase only, and others in a mixture of
uppercase and lowercase. Literal text may contain symbols, such
as hyphens. While the names of some drugs have hyphens (e.g.,
“GAMMA-HYDROXYBUTYRIC ACID”), use of hyphens in drug
names can vary across death certificates, which complicates
the identification of mentions of these drugs in literal text. Drug
names (particularly generic drug names) generally do not include
numbers, although numbers may be informative in clarifying the
extent of drug exposure (such as in the phrase “BLOOD LEVEL
≥ 20 MG/DL”). To simplify analyses, all text was converted to
uppercase, and symbols and numbers were removed.
Specificity of drug information–The specificity of drug
information varies across death certificates. Death certificates
may have mentions of specific drugs in the literal text (e.g.,
“OXYCODONE” or “FENTANYL”), mentions of drug classes
(e.g., “OPIOID”), or exposures not otherwise specified (NOS)
(e.g., “DRUG,” “CHEMICAL,” or “POLYPHARMACY”). Death
certificates may have a mixture of mentions of specific drugs,
drug classes, and exposures NOS. When a specific drug is
mentioned alongside mentions of drug classes or exposures
NOS, the mentions are sometimes referential (e.g., heroin
is assumed to be the opioid in the phrase “OPIOID (HEROIN)
OVERDOSE”).
Synonyms–A specific drug may be referenced by various
terms that are synonymous. For example, acetaminophen
(generic name), paracetamol (generic name), and APAP
(abbreviation) all refer to the same drug. When referring to
a single-ingredient product, Tylenol (brand name) is also
synonymous with acetaminophen. Brand names can refer to
products with one or more drug ingredients. Literal text can have
plural forms of drug mentions (e.g., mentions of “DRUGS,” the
plural form of drug). Literal text can also include misspellings.
While drug metabolites are not synonymous with the parent drug
products, drug metabolites may appear in the literal text, and are
assumed to be the same. For example, a literal text mention of a
toxicological finding of desmethyldiazepam (metabolite) would
indicate exposure to diazepam (the parent drug).
Contextual information–Mentions of drugs are often
accompanied by contextual information, which are other
words in the literal text that either describe the drug(s) or
provide information on how it was involved in mortality, if at
all. The words in proximity to the drug mentions provide more
informative contextual information than words that are distant.
Contextual information can provide details on drug
characteristics or characteristics of drug exposure, such as the
number of drugs (e.g., “MULTIPLE DRUGS”), extent of drug
exposure (e.g., “FATAL LEVEL OF DRUG” or “THERAPEUTIC
AMOUNT OF DRUG”), drug formulation (e.g., “DRUG TABLET”),
the type of drug (e.g., “ILLICIT DRUG” or “DRUGS WHICH
WERE PRESCRIBED”), and possession or ownership of the
drug (e.g., “HIS DRUG” or “HER DRUG”). These descriptions
can be complex and use conjunctions, such as the word “AND”
(e.g., “FATAL LEVEL OF PRESCRIPTION DRUGS ILLEGALLY
OBTAINED” and “ILLEGAL AND PRESCRIPTION DRUGS”).
Contextual information can also explicitly describe how
the drug exposure was involved in the death (e.g., “HEROIN
POISONING” and “ANAPHYLAXIS DUE TO ANTIBIOTIC”) or other
aspects of drug involvement. Other aspects of drug involvement
include route of administration (e.g., “DRUG INJECTION”),
medical history with drug exposure (e.g., “HISTORY OF DRUG
ABUSE” or “THERAPEUTIC USE OF METHADONE”), and
other complications with drug exposure (e.g., “DRUG-DRUG
INTERACTION”). Contextual information can also indicate drug
exposure, either explicitly (e.g., “USE OF DRUG”) or implicitly
(e.g., “DRUG BLOOD LEVEL 20 MG/DL”).
The contextual information can also be used to determine
whether the drug mentioned in the literal text was not involved
in mortality. For example, the drug “METHICILLIN” in the phrase
“METHICILLIN RESISTANT STAPHYLOCOCCUS AUREUS
INFECTION” does not suggest drug involvement in mortality, but
rather a type of bacterial infection. Similarly, the phrase “NOT
DRUG RELATED” clearly indicates that a death did not involve
drugs. This report distinguishes between a drug mention, a drug
mentioned with involvement (DMI), and a DMI death.
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• A drug mention is any mention of a drug, a drug class, or
exposure NOS in the literal text fields.
• A DMI is defined as a mention of a drug, a drug class, or
exposure NOS in the literal text fields, excluding mentions
where the contextual information suggested that the drug
was not involved in the death.
• A DMI death is defined as a death having at least one DMI.
Information in the literal text can be contextual in that it
provides information about drug characteristics or characteristics
of drug exposure (i.e., descriptors), or contextual in that it
describes whether and how a drug was involved in mortality
(i.e., contextual phrases). Although descriptors provide some
detail about the drugs mentioned in the literal text, they provide
little or no information about drug involvement and, therefore,
for the purposes of developing the literal text methodology, are
less important than contextual phrases.
Multiple drugs–Deaths may involve multiple drugs.
Medical certifiers may list these drugs consecutively, but not
necessarily in order of importance to the cause of death (e.g.,
alphabetical order). These sequential drug mentions may be
written with conjunctions, such as the word “AND” in the phrase
“METHICILLIN AND VANCOMYCIN.” Other sequential drug
mentions do not contain conjunctions, such as in the phrase
“OVERDOSE (HEROIN, COCAINE).”
While keyword searches can be performed to identify drug
mentions, keyword searches are not efficient in identifying the
contextual information associated with each drug mention.
This is because the same contextual information may relate to
more than one drug. For example, an infection that is resistant
to both methicillin and vancomycin is inferred in the phrase
“METHICILLIN AND VANCOMYCIN RESISTANT INFECTION.”
In the example, a search for “METHICILLIN RESISTANT
INFECTION” would not identify the mention of methicillin, and a
search for “METHICILLIN” would fail to identify that methicillin
was not involved in mortality.
Searching for statements that incorporate both drug mentions
and contextual information (e.g., searching for the statement
“METHICILLIN AND VANCOMYCIN RESISTANT INFECTION”)
is the most direct approach for simultaneously identifying drug
mentions and associated contextual information. However, this
approach would require a vast number of statements due to
the large number of drugs that can be mentioned, variability in
the order of the drug mentions, and variability in the contextual
information. In summary, there is an inexhaustible variety of
combinations of statements consisting of drug mentions and
contextual information.
Assessment of the presence of uninformative
literal text
The quality of the literal text and its potential utility in
identifying drug mentions was assessed by determining the
percentage of records with no information that could be used
to assign the cause(s) of death. The literal text was considered
uninformative if: 1) there was no text in any of the literal text
fields (i.e., the fields were blank) or 2) the fields only contained
descriptive words or phrases about the status of the investigation
(e.g., mentions of “PENDING” or “UNDER INVESTIGATION”).
In most cases, when all the literal text is uninformative, an
underlying cause-of-death of ICD–10 code R99 (Other ill-
defined and unspecified causes of mortality) is assigned. Figure
2 contains all the terms considered to be uninformative for the
purposes of identifying drug mentions.
Among NVSS–M records merged with literal text data
for year 2013 (the most recent year of data at the time of the
assessment), a small minority (less than 1%) had blank or
uninformative literal text (Table A). Most of these were assigned
an underlying cause-of-death code R99 (Other ill-defined and
unspecified causes of mortality). Therefore, a small minority
(less than 1%) of all records have literal text fields and ICD–10
coding that provide no information on specific causes of death.
Exchangeability: Optimizing efficiency of
processing literal text information
Manual review of the literal text revealed that drug mentions
are exchangeable (i.e., conceptually similar) when contextual
information is fixed. For example, the word “HEROIN” in the
phrase “HEROIN OVERDOSE” could be replaced (i.e., exchanged)
with the word “OPIOID,” with no change in the broad interpretation
of the literal text (i.e., the cause of death was a drug overdose).
Combinations of drug mentions are also exchangeable. For
example, “METHICILLIN AND VANCOMYCIN” is exchangeable with
the word “ANTIBIOTIC” in the phrase “ANTIBIOTIC RESISTANT
INFECTION.” Descriptors are also exchangeable. For example, the
word “RX” can replace the descriptor “MULTIPLE PRESCRIPTION”
in the phrase “MULTIPLE PRESCRIPTION DRUGS.”
CAUSE UNDER INVESTIGATION, DEFERRED, PENDING, PENDING ADDITIONAL STUDIES, PENDING ADDITIONAL STUDY, PENDING
AUTOPSY, PENDING AUTOPSY AND HISTOLOGY, PENDING AUTOPSY AND TOXICOLOGY, PENDING AUTOPSY HISTOLOGY, PENDING
AUTOPSY TOXICOLOGY, PENDING AUTOPSY FINDING, PENDING AUTOPSY FINDINGS, PENDING AUTOPSY STUDIES, PENDING
AUTOPSY STUDY, PENDING FURTHER INVESTIGATION, PENDING FURTHER STUDIES, PENDING FURTHER STUDY, PENDING
HISTOLOGY, PENDING HISTOLOGY AND AUTOPSY, PENDING HISTOLOGY AND TOXICOLOGY, PENDING HISTOLOGY AUTOPSY,
PENDING HISTOLOGY STUDIES, PENDING HISTOLOGY STUDY, PENDING HISTOLOGY TOXICOLOGY, PENDING LABORATORY
STUDIES, PENDING LABORATORY STUDY, PENDING INVESTIGATION, PENDING TOXICOLOGY, PENDING TOXICOLOGY AND
AUTOPSY, PENDING TOXICOLOGY AND HISTOLOGY, PENDING TOXICOLOGY AUTOPSY, PENDING TOXICOLOGY HISTOLOGY,
PENDING TOXICOLOGY STUDIES, PENDING TOXICOLOGY STUDY, PENDING STUDIES, PENDING STUDY, PENDING TOX UNDER
INVESTIGATION.
SOURCE: NCHS, National Vital Statistics System, death certificate literal text.
Figure 2. Literal text strings considered uninformative for assigning cause of death and identifying drug mentions
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The exchangeability of drug mentions enables the DMI
programs to more efficiently process data on drug mentions and
their associated contextual information. For example, replacing
sequential drug mentions identified in the literal text (e.g.,
“METHICILLIN AND VANCOMYCIN” or “VANCOMYCIN AND
METHICILLIN”) with the word “DRUG” greatly simplifies the
processing steps for the DMI program.
A stepwise approach was used to enhance the DMI
program efficiency in extracting information from the literal
text. This stepwise approach leverages the exchangeability of
drug mentions and the exchangeability of descriptors. In other
words, contextual information on drug involvement can be most
efficiently identified and processed using the computer algorithms
when the variability in drug mentions and associated descriptors
is reduced. This stepwise approach required the development of
lists of drugs, descriptors, and joining phrases that link search
terms or descriptors together, and the development of contextual
phrases.
Developing a search term list for drugs
A list of search terms was developed to identify drug
mentions. This list was developed using a two-phase approach.
The final list of search terms included single words (e.g.,
“HEROIN”) and combinations of words (e.g., “CRACK COCAINE”)
for specific drugs, drug classes, and drug exposures NOS.
In the first phase, the search term list was constructed from
single-word generic names listed in the Substance Abuse and
Mental Health Services Administration’s (SAMHSA) Drug Abuse
Warning Network (DAWN) Drug Reference Vocabulary (DRV),
published in 2012 (19). DAWN DRV is a drug vocabulary and
classification system based on the Multum Lexicon database
from Cerner Multum, Inc. Its structure is hierarchical with
generic drugs categorized under higher-level groupings (e.g.,
drug class). For use with the DAWN data system, SAMHSA
added substances that are misused and abused (e.g., illicit drugs
and inhalants) that were not included in the Multum Lexicon
database.
During this first phase of generating the search term
lists, the following DAWN DRV categories were excluded:
major substances of abuse, nutritional products, alternative
medicines, medical gases, biologicals, immune globulins,
immunostimulants, sterile irrigating solutions, and drugs
unknown. Products in these categories had generic names that
were difficult to condense into a single word denoting a drug
product. The list also excluded combination products, nearly all
of which could be identified by their components. The search
term list that resulted from the first phase of development did not
include names of drug classes or drug exposures NOS.
In the second phase, the search term list was expanded
by adding terms for specific drugs not identified in the first
phase, including illicit drugs; drug classes; drug exposures
NOS; terms containing more than one word; brand names; and
obvious, frequently occurring misspellings. Most of the search
terms added during the second phase were identified through
nonsystematic manual reviews and queries of the 2003–2014
literal text.
Methods development was focused on literal text data from
2007, the first year of literal text data that was available during
methods development, and from 2013, the most recent year of
data available at the time when assessments were conducted.
Additional search terms for brand names of prescription drugs
were identified using the Drugs@FDA website, and search terms
for misspelled drugs were identified using FDA Adverse Event
Reporting System data (20). A few search terms were also
identified using other approaches, including comparison with
ICD–10 codes.
The search term list that resulted from the second phase
excluded foods and food additives (e.g., starch), excipients, gases
(e.g., helium and carbon monoxide), airborne contaminants
(e.g., soot), industrial chemicals (e.g., ethylene glycol), periodic
table elements (e.g., lithium and iodine), and substances with
unknown industrial or pharmaceutical applications. Although
therapeutic uses of some of these substances is possible,
these substances were not included because it proved difficult
to determine whether the exposures to the substances were
therapeutic, for misuse or abuse, or environmental.
Study team members trained in pharmacy and
pharmacoepidemiology categorized search terms by various
characteristics, including whether the terms referred to specific
drugs, drug classes, or exposures NOS. Search terms were also
classified by whether they represented generic drug names or
other variants, such as brand names, common use or street
names, abbreviations, metabolites, and misspellings. Most
search terms were mapped to a single “principal variant,” the
overarching label assigned to a drug, a drug class, or exposure
NOS. In general, the principal variant was the generic drug name.
Some search terms—mostly for combination drug products—
were mapped to two or more principal variants. The use of
principal variants made it possible to identify all deaths that
involved the same drug.
Table A. Deaths having no informative literal text on cause of death: U.S. residents, 2013
Characteristics Number of deaths Percent of deaths
All deaths . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2,596,993 100.00
Deaths having no informative literal text . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3,831 0.15
Deaths having no informative literal text and ICD–10 code R99 as underlying cause of death1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3,421 0.13
1The ICD–10 code R99 indicates Other ill-defined and unspecified causes of mortality.
NOTE: ICD–10 is the International Classification of Diseases and Related Health Problems, Tenth Revision.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text.
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The development of the search term list involved various
efforts to create a comprehensive list of all drugs mentioned in
literal text. Although many methods were used to develop the
list, the list might not contain all possible search terms for all
possible drugs. The assessments conducted during methods
development were based on a June 2015 list of 2,865 search
terms representing 1,649 principal variants (see Table I–1). This
list was updated in November 2015 to include 3,116 search
terms representing 1,643 principal variants (see Table I–2).
Developing lists of contextual information
Three lists of contextual information were developed using
iterative manual reviews and queries of literal text for data years
2003 through 2014. The three lists consisted of descriptors,
joining phrases, and contextual phrases.
The list of descriptors included a word or words that provide
information on drug characteristics or characteristics of drug
exposure, such as “MULTIPLE,” “PRESCRIPTION,” and “NON
PRESCRIPTION.” The list classified whether the descriptor
should be identified before a drug mention, after a drug mention,
or either before or after a drug mention (as would be the case for
the descriptor “PRESCRIPTION” in the phrases “PRESCRIPTION
DRUG” and “DRUG PRESCRIPTION”). The list also classified
the descriptors by the characteristic(s) they aim to describe
(e.g., “TABLET” and “TRANSDERMAL” describe type of drug
formulation).
The list of joining phrases included words and asterisks
that acted as conjunctions. For this list, each joining phrase was
comprised of 1) two asterisks that indicate exchangeability of either
drug mentions or descriptors and 2) potentially other words that
indicate linkage. Examples of words that indicate linkage include
“AND” and “AS WELL AS.” Bookending these words were asterisks,
as in the case of the joining phrases “* AND *” and “* AS WELL
AS *.” These asterisks were exchangeable with drug mentions or
descriptors, as in the phrases “METHICILLIN AND VANCOMYCIN”
and “ILLICIT AS WELL AS PRESCRIPTION.” The simplest joining
phrase was “* *,” indicating two adjacent drug mentions or two
adjacent descriptors.
The list of contextual phrases included words and asterisks
that, altogether, describe drug involvement (if any). Examples
of contextual phrases include “* TOXICITY” and “ABUSED *.”
Like the asterisks in joining phrases, asterisks in contextual
phrases indicate exchangeability of mentions. However, while
the asterisks in joining phrases refer to either drug mentions or
descriptors, the asterisks in contextual phrases simultaneously
refer to drug mentions, any associated descriptors, and joining
phrases. In addition, while there are only two asterisks in joining
phrases, contextual phrases may have one or more asterisks,
as in the case of “ACCIDENTAL * TOXICITY WITH *,” which
could refer to the phrase “ACCIDENTAL DRUG TOXICITY WITH
HEROIN AND OTHER ILLICIT DRUGS.” The simplest contextual
phrase was “*,” indicating the mention of one or more drugs and
associated descriptors, but no other contextual information.
Study team members classified the contextual phrases by
various characteristics. The most important characteristic was
whether the contextual phrase did not suggest drug involvement.
Contextual phrases that suggested no drug involvement generally
referred to health conditions or disease states. For example,
when the word “INSULIN” replaces “*” in the contextual phrase
“* DEPENDENT DIABETES,” the resulting text refers to a health
condition. Similarly, when the word “METHICILLIN” replaces
“*” in the contextual phrase “* RESISTANT STAPHYLOCOCCUS
AUREUS INFECTION,” the resulting text refers to a type of
bacterial infection. Other contextual phrases clearly indicated no
drug involvement, which would be the case for the contextual
phrase “NO * INVOLVED.”
The drugs mentioned in the death certificate literal text
were assumed to be involved in the death unless contextual
information suggested otherwise.
Contextual phrases that described similar ideas (such as
“* TOXICITY” and “TOXICITY FROM *”) were classified under
a common category. Some phrases were classified under more
than one category; for example, “TOXICITY FROM * INJECTION”
was classified under the category for toxicity and the category
for injection.
The assessments conducted during methods development
were based on 527 descriptors, 22 joining phrases, and 1,641
contextual phrases that were listed as of June 2015. These lists
were updated in November 2015.
Identifying mentions of drugs and ascribing
context
Using SAS Version 9.3 (21), a suite of software programs
(referred to as the DMI programs) was developed to automate
the identification of drug mentions in the literal text and to
determine possible involvement of the drug in the death based
on contextual information.
Figure 3 provides an example of the application of the
DMI program logic to the following death certificate literal text:
“INGESTED ILLICIT AND RX DRUGS (HEROIN AND METHADONE);
HX OF OPIOID ABUSE.” Leveraging the exchangeability of
drug mentions and the exchangeability of descriptors, the DMI
programs use five steps to identify drug mentions and ascribe
context to each drug mention (Figure 3).
The first step prepares the literal text, resulting in text that
does not have symbols, numbers, and double spaces, and is
formatted in uppercase letters.
The second step uses the list of search terms to identify
drug mentions in the literal text. During this step, a new record is
generated for every search term (i.e., drug mention) identified in
the literal text. The DMI programs also identify simple plural forms
(i.e., search term plus the letter “S”). In the example in Figure
3, the DMI programs generate four records for the mentions of
“DRUGS,” “HEROIN,” “METHADONE,” and “OPIOID.”
Using the list of descriptors, the DMI programs iteratively
identify descriptors for each drug mention in the third step.
In the first iteration, the DMI programs identify and map
descriptors (such as “RX”) to adjacent drug mentions (such as
the mention of “DRUGS”), resulting in a drug mention with a
simple description (e.g., “RX DRUGS”). Subsequent iterations
use the list of joining phrases and list of descriptors to form
more complex descriptions. In the example, the DMI programs
link the descriptor “ILLICIT” and the descriptor “RX” with the
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Ingested illicit and Rx drugs (heroin and methadone); Hx of opioid abuse
Literal text
Step 1. Remove symbols, numbers, and double-spaces; convert all characters to uppercase
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
Step 2. Identify drug mentions
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
DRUGS
HEROIN
METHADONE
OPIOID
Identified
drug
mentions
ALCOHOL
DRUG
HEROIN
METHADONE
OPIOID
Example
search
terms
Step 3. Map descriptors to the drug mentions
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
DRUGS
HEROIN
OPIOID
ILLICIT AND RX
METHADONE
Identified
drug
mentions Identified
descriptors
ILLICIT
MULTIPLE
PRESCRIPTION
RX
Example
descriptors
Step 3 also identifies complex descriptions (e.g., “ILLICIT AND RX“) by linking descriptors (e.g., “ILLICIT” and “RX”) with joining
phrases (e.g., “* AND *”)
Step 4. Replace (consecutive) drug mentions and associated descriptors with a single asterisk (“*”)
consecutive drug mentions and associated descriptors
INGESTED ILLICIT AND RX DRUGS HEROIN AND METHADONE HX OF OPIOID ABUSE
drug mention
Step 5. Identify and map contextual phrases to the appropriate drug mention(s)
INGESTED * HX OF * ABUSE
INGESTED * HX OF * ABUSE
INGESTED * HX OF * ABUSE
INGESTED * HX OF * ABUSE
DRUGS
HEROIN
OPIOID
ILLICIT AND RX
METHADONE
Identified
drug
mentions Identified
descriptors
INGESTED * HX OF * ABUSE
INGESTED * HX OF * ABUSE
INGESTED * HX OF * ABUSE
INGESTED * HX OF * ABUSE
DRUGS
HEROIN
OPIOID
METHADONE
* POISONING
ABUSED *
INGESTED *
HX OF * ABUSE
ILLICIT AND RX INGESTED *
Identified
drug
mentions
Example
contextual
phrase Identified
descriptors
Identified
contextual
phrase
INGESTED *
HX OF * ABUSE
INGESTED *
NOTE: In this example, the DMI (drug mentioned with involvement) programs identify three drug mentions (“DRUGS,” “HEROIN,” “METHADONE”) in the literal text and map these drug
mentions to one contextual phrase (“INGESTED *”). The DMI programs also identify one drug mention ("OPIOID") and map this drug mention to one contextual phrase (“HX OF * ABUSE”).
SOURCE: NCHS, Division of Vital Statistics.
Figure 3. Example of the application of the DMI program logic to the literal text
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joining phrase “* AND *” to form the more complex description
“ILLICIT AND RX.” The resultant drug mention and associated
descriptors are subsequently more complex (e.g., “ILLICIT AND
RX DRUGS”).
The fourth step replaces drug mentions and associated
descriptors with a single asterisk “*” and also replaces
consecutive drug mentions and associated descriptors with
a single asterisk “*.” This step also uses joining phrases to
determine whether drug mentions are consecutive. For example,
using the joining phrase “* AND *,” the mention of “HEROIN”
and the mention of “METHADONE” are consecutive in the text
“HEROIN AND METHADONE.” Similarly, with the joining phrase
“* *,” the mention of “ILLICIT AND PRESCRIPTION DRUGS”
and “HEROIN” are consecutive mentions. In the example, the
mention of “OPIOID” is not listed consecutively with other drug
mentions.
Using the list of contextual phrases, the fifth step
identifies and maps contextual phrases to the appropriate drug
mention(s), that is, the drug mentions that were replaced in step
4. In the example, the mentions of “DRUGS,” “HEROIN,” and
“METHADONE” are mapped to the contextual phrase “INGESTED
*,” while the mention of “OPIOID” is mapped to the contextual
phrase “HX OF * ABUSE.”
Each search term is mapped to only one contextual phrase.
To optimize the mapping procedures, contextual phrases with
asterisks located between other words (e.g., “HX OF * ABUSE”)
are mapped before contextual phrases with asterisks located at
the end of the contextual phrase (e.g., “INGESTED *”).
Data produced by applying the literal text
analysis methodology
Application of the literal text analysis methodology results in a
data set of decedents, drug mentions, and contextual information
associated with each drug mention (Figure 3). The drug mentions
are categorized by principal variant and whether the drug mentions
refer to specific drugs, drug classes, or exposures NOS. The
contextual phrases are categorized by indication of involvement
of drugs in death. When the processed literal text data are linked
with NVSS–M data, the ICD–10 underlying and multiple cause-of-
death codes, demographic information, geographic information,
and other information in the multiple cause-of-death file are also
available.
In this report, the literal text analysis methodology was
applied to NVSS–M data linked with literal text for year 2013 as
an example. For this analysis, mentions of alcohols, tobacco, and
nicotine were excluded, as they are involved in many deaths that
do not involve other drugs.
Table B shows the number of U.S. resident deaths with
drug mentions and DMIs based on the 2013 literal text. Of the
approximately 2.6 million deaths in 2013, 114,621 had at least
one drug, alcohol, tobacco, or nicotine mention. The number of
deaths with a drug mention was 72,518. The number of deaths
with at least one drug mention and no contextual information
indicating that the drug was not involved in the death (DMI) was
65,062. Among these deaths, there were 150,342 DMIs, for an
average of 2.3 DMIs per death.
Table C shows the level of specificity of the drug mentions
(i.e., whether the drug mention was a specific drug, a drug class,
or an exposure NOS) for the 65,062 DMI deaths in 2013. The
majority of DMIs referred to a specific drug (58%). Most of
the specific drug mentions were generic names (82,895 DMIs,
Table B. Deaths with drug mentions and mentions of drug involvement: U.S. residents, 2013
Characteristics Number of deaths Number of mentions
Deaths among U.S. residents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2,596,993 …
Deaths with at least one drug, alcohol, tobacco, or nicotine mention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 114,621 216,361
Deaths with at least one drug mention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72,518 158,104
Deaths with at least one DMI (drug mentioned with involvement in death) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65,062 150,342
… Category not applicable.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text.
Table C. Number and percentage of DMIs, by level of specificity of the drug mention: U.S. residents, 2013
Type of DMI Number Percent
All DMIs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 150,342 100.0
Specific drug . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87,764 58.4
Drug class . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8,979 6.0
Exposure not otherwise specified1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53,599 35.7
1Category includes nonspecific references to drugs (e.g., mention of “POLYPHARMACY” or “DRUG”).
NOTES: Mentions of alcohols, tobacco, and nicotine were excluded from the analyses. DMI is a drug mentioned with involvement in the death.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with literal text data.
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or 95%), while the remainder of the specific drug mentions
were other variants, such as brand names and misspellings.
Slightly more than one-third of all DMIs (36%) were nonspecific
references to drugs.
Similarly, DMI deaths can be categorized by the highest level
of specificity of the drugs involved. Table D shows the number
of DMI deaths from 2013. Of the 65,062 DMI deaths, 69% had
mentions of at least one specific drug, while 7% had mentions of
a drug class but not a specific drug. For 24% of the deaths, only
nonspecific drug references were found (i.e., neither a drug class
nor specific drug were mentioned).
Assessments of the literal text analysis
methodology
Two assessments examined the performance of the literal
text analysis methodology in identifying DMIs and DMI deaths.
The assessments were conducted using NVSS–M data linked
with literal text for year 2013.
The first assessment examined the agreement between data
produced by the DMI programs and ICD–10 coded data for three
selected drugs. In the ICD–10 classification system, there are
a few T codes, F codes, and R codes that identify deaths with
poisonings, mental and behavioral disorders, and toxicological
findings related to specific drugs, respectively. These specific
drugs include cocaine, heroin, and methadone. The ICD–10 rules
for assigning codes in mortality can be found elsewhere (17).
Comparisons were made between the numbers of DMI deaths
identified by the DMI programs and the numbers of deaths
identified as having one of the specific T, F, or R codes for cocaine,
heroin, or methadone (Table E). Considering the differences
between the DMI definition (i.e., a drug was mentioned and there
was no contextual information indicating that the drug was not
involved in the death) and the ICD–10 definitions and rules for
assigning T, F, and R codes, there was high agreement (greater
than 90%) between the DMI programs and the ICD–10 codes
in the identification of deaths involving cocaine, heroin, and
methadone (Table E).
The second assessment examined the accuracy of the DMI
programs in identifying DMIs and DMI deaths. This assessment
was based on two subsets of mortality records that were
likely to have DMIs: 1) deaths selected by the application of
the DMI programs to mortality records and 2) deaths with no
uninformative literal text fields and selected using ICD–10 entity
axis codes that likely pertained to a drug-involved mortality. These
codes included ICD–10 codes referring to mental or behavioral
disorders due to psychoactive substance use, poisonings,
adverse effects due to drugs and alcohol, and ICD–10 codes
whose title or definition explicitly indicated drug involvement
(e.g., P04.4 Fetus and newborn affected by maternal use of
drugs of addiction) (Figure 4). ICD–10 codes that only indicated
alcohol, tobacco, or nicotine involvement were excluded from
the list of selected ICD–10 codes. In summary, the codes used
in the analysis included those typically used to identify drug
overdose deaths and those that indicated other drug involvement
(e.g., anaphylaxis) (2,22).
From the pool of mortality records identified by either of
the two selection methods, a simple random sample of 2,000
records was taken and manually reviewed to determine whether
drug mentions in the literal text (if any) met the definition of a DMI
Table E. Agreement between DMI programs and selected ICD–10 codes: U.S. residents, 2013
Referent drug
ICD–10 code(s) that
apply to referent drug1
Deaths with DMI of
referent drug2 [A]
Deaths with ICD–10
code(s) that apply to
referent drug3 [B]
Deaths with either
DMI of referent
drug or ICD–10
code(s) that apply
to referent drug [C]
Deaths with both referent
drug mention and ICD–10
code(s) that apply to
referent drug [D] D/A x 100 D/B x 100 D/C x 100
Cocaine . . . . . . . . . . T40.5, F14.–, R78.2 7,324 7,176 7,361 7,139 97.4 99.5 97.0
Heroin . . . . . . . . . . . T40.1 8,924 8,360 8,968 8,316 93.2 99.5 92.7
Methadone . . . . . . . T40.3 4,005 3,737 4,029 3,713 92.7 99.4 9.2
1ICD–10 codes used in this analysis were entity axis codes.
2The DMI programs identify deaths with mention of the referent drug in the literal text fields, excluding mentions where the contextual information suggested that the drug was not involved in
the death.
3The listed T codes, F codes, and R codes identify deaths due to poisonings, mental and behavioral disorders, and toxicological findings related to the referent drug, respectively.
NOTES: DMI is a drug mentioned with involvement in the death. ICD–10 is International Classification of Diseases and Related Health Problems, Tenth Revision.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text.
Table D. Number and percentage of DMI deaths, by level of specificity of the DMI: U.S. residents, 2013
Type of DMI Number Percent
All DMI deaths . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65,062 100.0
Deaths with mention of at least one specific drug . . . . . . . . . . . . . . . . . . . . . . 45,035 69.2
Deaths with mention of a drug class only . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4,560 7.0
Deaths without mention of a drug class or specific drug1 . . . . . . . . . . . . . . . . 15,467 23.8
1Category includes DMI deaths with mentions of nonspecific drug references (e.g., mention of “POLYPHARMACY” or “DRUG”).
NOTES: Mentions of alcohols, tobacco, and nicotine were excluded from the analyses. DMI is a drug mentioned with involvement in the death.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with literal text data.
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and whether the sampled record reflected a true DMI death. The
results from the manual review served as the “gold standard.”
The performance of the DMI programs to identify DMIs and
DMI deaths was quantified using the following measures: true
positives, false positives, false negatives, true negatives (only
calculated for deaths, not drug mentions), and positive predictive
values (PPVs). Each drug mention was categorized as either a
true-positive mention (identified by both the DMI programs and
by manual review), a false positive mention (identified by the
DMI program but not the manual review), or a false negative
mention (identified by manual review but not the DMI program).
Reasons that a mention was categorized as false positive or false
negative were described.
Similarly, each death was categorized as either a true-
positive death, false positive death, or false negative death.
True-negative deaths were identified only by ICD–10 codes, but
were not categorized as DMI deaths according to manual review.
PPVs quantified the percentage of DMIs or DMI deaths correctly
identified as such by the DMI programs (i.e., true positives/[true
positives + false positives]). Measures of sensitivity and specificity
could not be calculated because the selected records were not
randomly sampled from all mortality records.
From the application of the DMI programs, 65,062 deaths
were identified as possible DMI deaths in 2013. From selection
based on ICD–10 codes (Figure 4), 61,282 deaths were identified as
likely pertaining to drug involvement. Combined, the two methods
identified 69,493 unique deaths with possible drug involvement. A
majority of these deaths (56,851 or 81.8%) was identified by both
methods, while a minority of these deaths (4,431 or 6.4%) was
only identified using ICD–10 codes. The remaining deaths (8,211
or 11.8%) were identified by the DMI programs only.
The 2,000 randomly sampled deaths included 1,808 deaths
identified using ICD–10 codes, of which 1,691 deaths were also
identified by the DMI programs. The remaining 192 deaths in the
sample were only identified by the DMI programs.
The DMI programs identified DMIs with high accuracy
(Table F). According to manual review of literal text, 4,357 (97%)
of the 4,487 mentions identified by the DIM programs were true-
positive mentions, while the remaining 130 mentions (3%) were
categorized as false positive. The DMI programs failed to identify
52 mentions of drugs involved in mortality. Some deaths may
have a mixture of true-positive, false-positive, and false-negative
mentions in their literal text.
The DMI programs also identified DMI deaths with high
accuracy (Table G). According to manual review of literal text for
deaths identified using ICD–10 codes, 1,804 of the 1,883 deaths
(96%) identified by the DMI programs were true-positive deaths,
while the remaining 79 deaths (4%) were categorized as false
positive. The DMI programs did not identify 100 deaths that did
not have drug involvement (true-negative deaths), but failed to
identify 17 deaths that did have drug involvement (false-negative
deaths). All 117 of these deaths were identified using ICD–10
codes.
The false-positive and false-negative mentions fell into
nine categories (Table H). In a few instances, the DMI programs
identified more text than should have been identified. For example,
the DMI programs identified a mention of “PAIN NARCOTIC”
instead of “NARCOTIC” in the literal text “BACK PAIN NARCOTIC
DEPENDENT.” In contrast, the DMI programs sometimes identified
one or more search terms that were nested in a longer drug name,
resulting in false-positive and false-negative mentions. The DMI
programs also identified false-positive mentions for other reasons,
including: search terms were not drugs, search terms were used
to describe health conditions and disease states, or contextual
information indicated no drug involvement. Manual review of literal
text also identified other reasons for false-negative mentions: drugs
mentioned in the literal text were not search terms, or a drug mention
was not separated by a space from other words in literal text.
The findings from the assessment were used to update and
improve the lists of search terms and contextual information.
A80.0, D52.1, D59.0, D59.2, D61.1, D64.2, D68.3, E03.2, E06.4, E16.0, E23.1, E24.2, E27.3, E66.1, F11–F16, F19, F55, G21.1, G24.0, G25.1,
G25.4, G25.6, G44.4, G62.0, G72.0, H26.3, H40.6, I42.7, I95.2, J70.2, J70.3, J70.4, K85.3, L10.5, L23.3, L24.4, L25.1, L27[.0–.1], L27[.8–.9],
L43.2, L56[.0–.1], L64.0, M10.2, M32.0, M34.2, M80.4, M81.4, M83.5, M87.1, N14[.0–.2], O35.5, P04[.0–.1], P04.4, P04[.8–.9], P58.4, P93,
P96[.1–.2], Q86[.1–.2], R50.2, R78[.1–.6], R78[.8–.9], R82.5, R83[.2–.3], R84[.2–.3], R85[.2–.3], R86[.2–.3], R87[.2–.3], R89[.2–.3], T36, T37,
T38, T39, T39[.1–.4, .8–.9], T42, T43–T50, T57[.8–.9], T65[.5, .8–.9], T88[.0–.1, .6–.7], T96, T97, X4T400–X44, X49, X60–X64, X69, X85,
X89–X90, Y10–Y14, Y19, Y40–Y47, Y49–Y59, Y88.0, Z03.6, Z72.2, Z91.0, Z92[.1–.2]
SOURCE: International Classification of Diseases and Related Health Problems, Tenth Revision (ICD–10).
Figure 4. ICD–10 entity axis codes likely pertaining to a drug-involved mortality
Table F. DMI programs’ ability to identify DMIs among a random sample of 2,000 deaths having one or more ICD–10 entity axis
codes or identified using the DMI programs: U.S. residents, 2013
Evaluation DMIs identified from the manual review
Yes No Total
DMIs identified by the DMI programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4,357 130 4,487
DMIs not identified by the DMI programs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 … …
… Category not applicable.
NOTES: See Figure 4 for list of entity axis codes. Positive predictive value calculated as: 4,357 mentions/4,487 mentions = 97.1%. DMI is a drug mentioned with involvement in the death.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text.
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Discussion
New method for identifying drug involvement
in death
The application of the literal text analysis methodology
described in this report can be used to enhance mortality
statistics by facilitating the identification of specific drugs
involved in drug overdose deaths and deaths with other drug
involvement. ICD–10 (6), which has historically been used to
classify the drugs involved in the deaths in NVSS–M, is limited in
that the vast majority of drugs are classified into broad categories.
For example, oxycodone, hydrocodone, and morphine are all
classified to T40.2 (Poisoning: Other opioids) (7). There are a few
notable exceptions, such as heroin (T40.1), methadone (T40.3),
and cocaine (T40.5), which are separately coded in the case of a
drug overdose death. In contrast, the methods described in this
report allow for the identification of drugs that are not uniquely
identified in ICD–10.
The identification of specific drugs provides flexibility
in analyses. Specific drugs can be categorized according to
classification schemes different than those of the ICD–10
categories. Identifying specific drugs also allows comparisons
between drugs within a particular class. In addition, identifying
specific drugs allows for more detailed analysis on deaths
involving multiple drugs that are classified to the same or even
different categories.
The literal text analysis methodology was developed to
extract information on the specific drugs involved in deaths
from the nonstructured literal text data obtained from death
certificates. Utility of the methodology depends on the quality
and quantity of information in literal text. The methodology will
not identify a drug mention among deaths whose literal text
only states “POISONING” or “OVERDOSE,” but does not have
any reference to drugs. Many issues were considered when
designing this methodology, including the unstructured nature
of the data, the number of drugs mentioned, the contextual
information describing the drug involvement, and the efficiency
of the programs to extract information on the drugs involved.
Ultimately, the methods that were developed imitate, to some
Table H. Reasons for false-positive and false-negative mentions in the assessment of the DMI programs to identify DMIs and DMI
deaths
Reason for false-positive or false-negative mention Example Result of assessment
Search term was not a drug DMI program identified “DIFLUOROETHANE,”
which is not a drug
Identified a false-positive mention
Search term used to describe health condition or
disease state
DMI program identified “FOLIC ACID” in text
“FOLIC ACID DEFICIENCY,” or identified “PCP,”
referring to pneumocystis pneumonia
Identified a false-positive mention
Drug mention nested in an identified search term DMI program identified “PAIN NARCOTIC” instead
of “NARCOTIC” in text
“BACK PAIN NARCOTIC DEPENDENT”
Identified a false-positive mention and
a false-negative mention
Search term was nested in a longer drug name DMI program identified “DRUG” in text “NON
STEROIDAL ANTIINFLAMMATORY DRUG”
Identified a false-positive mention and
a false-negative mention
Context adjacent to search term indicated no drug
involvement
DMI program identified “DRUG” in text “NO DRUG
INVOLVEMENT”
Identified a false-positive mention
Drug was not a search term “CONTRAST DYE” was not identified because it
was not a search term
Identified a false-negative mention
Drug name was not separated from other words in
literal text
DMI program failed to identify “ALPRAZOLAM” in
text “OPIOID ANDALPRAZOLAM OVERDOSE”
Identified a false-negative mention
NOTES: A false-positive mention indicates that the drug was identified by the DMI programs but not during the manual review. A false-negative mention indicates that the drug was identified
during the manual review but not by the DMI programs. DMI is drug mentioned with involvement.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text.
Table G. DMI programs’ ability to identify DMI deaths among a random sample of 2,000 deaths having one or more ICD–10 entity
axis codes or identified using the DMI programs: U.S. residents, 2013
Evaluation DMI deaths identified from the manual review
Yes No Total
DMI deaths identified by the DMI programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1,804 79 1,883
DMI deaths not identified by the DMI programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 100 117
NOTES: See Figure 4 for list of entity axis codes. Positive predictive value calculated as: 1,804 deaths/1,883 deaths = 95.8%. DMI is a drug mentioned with involvement in the death.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text.
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degree, the current processes used to identify statements in
death certificates for eventual translation into ICD–10 codes.
With the search terms, descriptors, and contextual phrases
identified, it is possible to approximately construct literal text
statements related to drug-involved mortality.
Development and maintenance of the DMI lists
and programs
The importance of creating comprehensive lists to be used
by the DMI programs cannot be overstated. The DMI programs
are a series of steps that identify drug mentions, descriptors of
those drug mentions, and other contextual information. Each
step of the processing of literal text requires lists: search terms,
descriptors, joining phrases, or contextual phrases. Incomplete
lists used by the DMI programs may result in failure in any of
the processing steps, which would result in a failure to associate
drug mentions with the appropriate contextual information.
The development of the lists used by the DMI programs
requires an understanding of the drugs of interest as well as
iterative manual reviews of literal text, and this development
process is time intensive. The high percentage of agreement
between the DMI programs and the manual review suggests
that the lists used by the DMI programs were generally
comprehensive. However, even with the careful development of
these lists, the DMI programs found a few mentions that did not
refer to drugs or failed to identify DMIs. For example, the DMI
programs found false-positive mentions of “PCP” that referred
to pneumocystis pneumonia, but the programs failed to find
mentions of “CONTRAST DYE,” which was a drug class that
was not a search term. Incompleteness in the list of contextual
phrases also yielded false-positive DMIs (e.g., identification of
“FOLIC ACID” in the text “FOLIC ACID DEFICIENCY”). These
false-positive and false-negative mentions demonstrate the
importance of careful development of these lists. Updating and
refining the lists used by the DMI programs will help resolve
these issues for future investigations.
This report found that a little over one-third of deaths
involving drugs did not include information on the death
certificate about the specific drug(s) involved. This finding from
the literal text analysis is consistent with other analyses of the
ICD–10 coded data (23). Efforts are underway in many states
to improve the specificity of drugs listed on death certificates
(24,25). It is possible that search terms for certain drugs rarely
seen in drug overdose deaths were not included despite the
multiple avenues taken to develop the list of search terms.
Future directions
Data from the literal text could potentially be used to detect
emerging trends in drug-involved mortality. For instance, the
methods used in this report could be modified to identify deaths
involving newly approved prescription drugs, new illicit drugs,
and other health threats. Furthermore, the software programs
used to mine the literal text could be modified to help identify
emergent trends in drug-involved mortality, even before the
annual mortality statistical files are finalized. With the rise of
synthetic drugs, such as the fentanyl analogs (26), this may
be necessary in the future. In order to detect emerging trends,
periodically updating the text search capabilities is critical to
surveillance of drug overdose deaths.
The amount of information that can be extracted from the
literal text is a function of the level of detail that certifiers provide.
There are general references that provide guidance on filling out
death certificates that describe the importance of details (27,28).
In addition to these general references, there is guidance for
certifying drug overdose deaths, which stresses the importance
of including the specific drugs involved (24). Because of the
importance of including the specific drugs on death certificates
for public health purposes, there are recommendations to help
epidemiologists develop partnerships to help improve specificity
of drugs on the death certificates (25).
Currently, the literal text analysis methodology focuses on
using the contextual information to identify the mentions of
drugs involved in the death. In the future, additional analysis
of the contextual information may be informative. For instance,
the method could be used to explore the route of administration
(e.g., inhalation, injection, or transdermal), specific drug effects
(e.g., anaphylaxis), and antibiotic resistance.
Conclusion
This report details a new method that was developed to
extract information from the National Vital Statistics System
death certificate literal text to improve national monitoring
of drug-involved mortality. The literal text analysis method
described in this report leverages existing information on the
death certificates for statistical monitoring of drug-involved
mortality deaths. Assessments conducted during the methods
development process demonstrate that these methods have
high accuracy in identifying the drugs mentioned and involved
in mortality as well as the corresponding deaths. These methods
could be applied to analyze mortality data for causes of death
classified to broad ICD categories or for emerging causes of
death with no ICD code assigned. Although the methods are
limited by the level of drug-specific detail provided in the death
certificate literal text, these methods are an enhancement to
current ICD–10-coded mortality data.
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Death. 2003 revision. Available from: http://www.cdc.gov/nchs/
data/dvs/death11-03final-acc.pdf.
17. National Center for Health Statistics. ICD–10 mortality manual
parts 2a, 2b, and 2s. Available from: http://www.cdc.gov/nchs/
nvss/instruction_manuals.htm.
18. Rowe M. Personal correspondence. 2016.
19. Center for Behavioral Health Statistics and Quality, Substance
Abuse and Mental Health Services Administration. Drug Abuse
Warning Network methodology report, 2010 update. 2010.
20. Food and Drug Administration. FDA Adverse Event Reporting System.
Available from: http://www.fda.gov/Drugs/InformationOnDrugs/
ucm135151.htm.
21. SAS Institute Inc. SAS (Release 9.3) [computer software]. 2012.
22. World Health Organization. International statistical classification
of diseases and related health problems, tenth revision (ICD–10).
2nd ed. Geneva, Switzerland. 2004.
23. Warner M, Paulozzi LJ, Nolte KB, Davis GG, Nelson LS. State
variation in certifying manner of death and drugs involved in drug
intoxication deaths. Acad Forensic Pathol 3(2)231–7. 2013.
24. Davis GG, National Association of Medical Examiners and
American College of Medical Toxicology Expert Panel on
Evaluating and Reporting Opiod Deaths. Complete republication:
National Association of Medical Examiners position paper:
Recommendations for the investigation, diagnosis, and
certification of deaths related to opioid drugs. J Med Toxicol
(10)1:100–6. 2014.
25. Sabel J, Poel A, Tuazon E, Paone D, Slavova S, Bunn T, et al.
Recommendations and lessons learned for improved reporting
of drug overdose deaths on death certificates. Council of
State and Territorial Epidemiologists. 2016. Available from:
http://c.ymcdn.com/sites/www.cste.org/resource/resmgr/PDFs/
PDFs2/4_25_2016_FINAL-Drug_Overdos.pdf.
26. Gladden RM, Martinez P, Seth P. Fentanyl law enforcement
submissions and increases in synthetic opioid-involved overdose
deaths—27 states, 2013–2014. MMWR Morb Mortal Wkly Rep
65(33)837–43. 2016. Available from: http://www.cdc.gov/mmwr/
volumes/65/wr/mm6533a2.htm.
27. National Center for Health Statistics. Medical examiners' and
coroners' handbook on death registration and fetal death
reporting. 2003. Available from: http://www.cdc.gov/nchs/data/
misc/hb_me.pdf.
28. Hanzlick R. Cause of death and the death certificate: Important
information for physicians, coroners, medical examiners, and the
public. North Field, IL: College of American Pathologists. 2006.
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National Vital Statistics Reports, Vol. 65, No. 9, December 20, 2016
Contents
Abstract ..
Introduction
Methods Development.
Overview .
Data source .
Considerations in developing methods to process
death certificate literal text
Assessment of the presence of uninformative literal text.
Acknowledgments
This joint project between the National Center for Health Statistics and the the
Office of Surveillance and Epidemiology within the Center for Drug Evaluation
and Research of the U.S. Food and Drug Administration (FDA) utilized the
information on deaths involving drugs captured in the National Vital Statistics
‘System-Mortality linked with death certificate literal text. The authors would like
to acknowledge the contributions of Dr. Louis An, a pharmacist with the Office of
Surveillance and Epidemiology who assisted in the verification of mappings from
the individual drug search terms to the principal variants.
Exchangeability: Optimizing efficiency of processing literal
text information
Developing a search term list for drugs .
Developing lists of contextual information.
Identifying mentions of drugs and ascribing context
Data produced by applying the literal text analysis methodology.
Assessments of the literal text analysis methodology
Discussion bees
New method for identifying drug involvement in death
Development and maintenance of the DMI lists and programs
Future directions .
Conclusion.
References.
Suggested citation
Trinidad JP, Warmer M, Bastian BA, et al. Using
literal text from the death certificate to enhance
mortality statistics: Characterizing drug
involvement in deaths. National vital statistics
reports; vol 65 no 9. Hyattsville, MD: National
Center for Health Statistics. 2016.
Copyright information
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or copied without permission; citation as to
source, however, is appreciated.
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National Center for Health Statistics
Charles J. Rothwell, M.S., M.B.A., Director
Jennifer H. Madans, Ph. )., Associate Director
for Science
n of Vital Statistics
Director
Hanyu Ni, Ph.D., M.P.H., Associate Director
for Science
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National Vital
Statistics Reports
Volume 67, Number 9
Need
December 12, 2018
Drugs Most Frequently Involved in Drug Overdose
Deaths: United States, 2011-2016
by Holly Hedegaard, M.D., M.S.P.H., and Brigham A. Bastian, B.S., National Center for Health Statistics;
James P. Trinidad, M.P.H., M.S., U.S. Food and Drug Administration; Merianne Spencer, M.P.H., and
Margaret Warner, Ph.D., National Center for Health Statistics
Abstract
Objective—this report identifies the specific drugs involved
most frequently in drug overdose deaths in the United States
from 2011 through 2016.
Methods—Record-level data from the 2011-2016 National
Vital Statistics System—Mortality files were linked to electronic
files containing literal text information from death certificates.
Drug overdose deaths were identified using the /nternational
Classification of Diseases, Tenth Revision underlying cause-
of-death codes X40-X44, X60-X64, X85, and Y10-Y14. Drug
mentions were identified by searching the literal text in three
fields of the death certificate: the causes of death from Part |,
significant conditions contributing to death from Part Il, and a
description of how the injury occurred. Contextual information
was used to determine drug involvement in the death. Descriptive
statistics were calculated for drug overdose deaths involving the
10 most frequently mentioned drugs. Deaths involving more
than one drug (e.g., a death involving both heroin and cocaine)
were counted in all relevant drug categories (e.g., the same death
was included in counts of heroin deaths and in counts of cocaine
deaths).
Results—Among drug overdose deaths that mentioned at
least one specific drug, the 10 most frequently mentioned drugs
during 2011-2016 included fentanyl, heroin, hydrocodone,
methadone, morphine, oxycodone, alprazolam, diazepam,
cocaine, and methamphetamine. Oxycodone ranked first in 2011,
heroin during 2012-2015, and fentanyl in 2016. During the study
period, cocaine consistently ranked second or third. From 2011
through 2016, the age-adjusted rate of drug overdose deaths
involving heroin more than tripled, as did the rate of drug
overdose deaths involving methamphetamine. The rate of drug
overdose deaths involving fentanyl and fentanyl analogs doubled
each year from 2013 through 2016, from 0.6 per 100,000 in
2013 to 1.3 in 2014, 2.6 in 2015, and 5.9 in 2016. The rate of
overdose deaths involving methadone decreased from 1.4 per
100,000 in 2011 to 1.1 in 2016. The 10 most frequently
mentioned drugs often were found in combination with each
other. The drugs most frequently mentioned varied by the intent
of the drug overdose death. In 2016, the drugs most frequently
mentioned in unintentional drug overdose deaths were fentanyl,
heroin, and cocaine, while the drugs most frequently mentioned
in suicides by drug overdose were oxycodone, diphenhydramine,
hydrocodone, and alprazolam.
Conclusions—this report identifies patterns in the specific
drugs most frequently involved in drug overdose deaths from
2011 through 2016 and highlights the importance of complete
and accurate reporting in the literal text on death certificates.
Keywords: opioid ¢ fentanyl heroin * cocaine * National Vital
Statistics System
Introduction
From 1999 through 2016, the age-adjusted rate of drug
overdose deaths in the United States more than tripled from 6.1
per 100,000 to 19.8 per 100,000 (1). Multiple studies have used
National Vital Statistics System—Mortality (NVSS—M) data, coded
using the /nternational Classification of Diseases, Tenth Revision
(ICD—10), to examine patterns of drug involvement in overdose
deaths (1-5). ICD—10 is the classification system used in the
United States to categorize the underlying and multiple causes of
death (6). One limitation of this classification system is that, with
afew exceptions, ICD-10 codes reflect broad categories of drugs
rather than unique specific drugs. For example, oxycodone and
hydrocodone are both classified in the same category of natural
and semisynthetic opioid analgesics (ICD-10 code 140.2). The
broad drug categorizations used in ICD-10 make it difficult to
use ICD-10-coded data to monitor trends in deaths involving
specific drugs (e.g., deaths involving oxycodone specifically).
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
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2 National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018
To address this limitation, the National Center for Health
Statistics (NCHS) and the U.S. Food and Drug Administration
(FDA) collaboratively developed methods to search the literal
text from death certificates to identify mentions of specific drugs
and other substances, and to search contextual terms to identify
involvement of the drug(s) or substance(s) in the death (7). The
literal text is the written information provided by the medical
certifier, usually a medical examiner or coroner in the case of
drug overdose deaths (8,9), and describes the cause of death
and other factors or circumstances that contributed to the death.
The methods developed by NCHS and FDA search three literal
text fields from the U.S. standard death certificate: the causes
of death from Part I, significant conditions contributing to death
from Part II, and a description of how the injury occurred (7,10).
A previous study presented the findings from use of literal
text analysis to identify the specific drugs most frequently
involved in drug overdose deaths from 2010 through 2014 (11).
This report uses the same methodology and an enhanced search
term list to provide results for drug overdose deaths from 2011
through 2016.
Methods
Data source and study population
NVSS–M data from 2011 through 2016 were used in this
descriptive analysis. NVSS–M data contain cause-of-death,
demographic, and geographic information extracted from death
certificates (12). The study population was limited to decedents
who were U.S. residents with an ICD–10 underlying cause-of-
death of drug overdose: X40–X44 (unintentional), X60–X64
(suicide or intentional self-harm), X85 (assault), and Y10–Y14
(undetermined intent). During the study period, the manner of
death was unintentional for 80%–86% of drug overdose deaths,
suicide for 8%–13%, homicide for 0.2%, and undetermined
intent for 6%–7% (1,13). The underlying cause-of-death codes
reflect deaths resulting from acute intoxication from drugs
(i.e., drug overdose). Deaths from chronic exposure to drugs
(e.g., liver toxicity) or adverse effects experienced from
therapeutic or prophylactic dosages of drug were not included.
Use of this code set (X40–X44, X60–X64, X85, and Y10–Y14)
is consistent with other NCHS publications on drug overdose
deaths and facilitates comparison with other analyses using the
ICD–10-coded data (1).
NVSS–M files were linked to electronic files containing
literal text data, also extracted from death certificates (7).
Mentions of drugs or other substances (described below) were
identified using the literal text data from three fields of the death
certificate: the causes of death from Part I, significant conditions
contributing to death from Part II, and a description of how the
injury occurred.
Identifying drug mentions and involvement of
the drug in the death
The method for searching literal text information to
characterize the drugs involved in deaths has been described
elsewhere (7). Briefly, the method involves searching the literal
text for mentions of drugs and other substances, as well as terms
that provide context about the involvement of the drug in the death
(i.e., whether the drug contributed to the death). For example, the
phrase “METHICILLIN RESISTANT STAPHYLOCOCCUS AUREUS
INFECTION” does not suggest drug involvement in mortality, but
rather a type of bacterial infection. Similarly, the phrase “NOT
DRUG RELATED” clearly indicates that the death did not involve a
drug, even though “DRUG” is mentioned in the phrase. The drug
or substance mentioned in a literal text field is assumed to be
involved in the death unless the contextual information indicates
otherwise. Software programs, referred to as the Drug Mention
with Involvement (DMI) programs, have been developed using
SAS version 9.4 to automate the process (7).
DMI programs identify mentions of drugs and other
substances using various search terms. Search terms include
generic drug names, brand names, common usage or street
names, abbreviations, metabolites, misspellings, and other
variations. The list of search terms used in this report is broader
than that used in a previous report (7), and was developed to
maintain as much substance specificity as possible. The new
search term list was applied to the literal text for all years of the
study (2011–2016). Because a new search term list was used
in this analysis, the results for 2011–2014 may differ slightly
from those reported previously (from 0 to 36 additional deaths
depending on the drug and the year) (11).
Each search term was mapped to a “principal variant,” the
overarching label assigned to a drug, a drug class, or exposure
not otherwise specified. For example, terms such as “COCAIEN”,
“COCAINE CRACK”, “COCAINE HYDROCHLORIDE”, and
“COCAINETOXICITY” were all mapped to the principal variant
“COCAINE”. In general, the principal variant was the generic
drug name. Some search terms—mostly for combination drug
products—were mapped to two or more principal variants. Use of
principal variants makes it possible to generate aggregate counts
for all search terms that refer to the same drug or substance.
Principal variants also were categorized according to whether
they referred to specific drugs or substances (e.g., methadone),
classes of drugs or substances (e.g., opioids), or nonspecific
references to exposures to drugs (e.g., words such as “DRUG”,
“MULTIDRUG”, or “POLYPHARMACY”). The DMI Search Terms
and principal variants table is provided in an accompanying
CSV file (https://ftp.cdc.gov/pub/Health_Statistics/NCHS/Program_
Code/oae/).
A frequency distribution of the principal variants identified
the top 20 drugs for each year from 2011 through 2016. A
referent drug category was created for each of the top 20
drugs. The term “referent drug” in the tables and figures in this
report generally refers to a single principal variant for the drug
of interest. However, due to the greater detail in the updated
principal variant list, some of the referent drug categories are
comprised of two or more principal variants, generally reflecting
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National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018 3
a drug and its metabolites. For example, the principal variant
HYDROCODONE and the principal variant NORHYDROCODONE
(a metabolite of hydrocodone) were grouped together to
create the referent drug category of HYDROCODONE. The
referent group FENTANYL included fentanyl as well as fentanyl
metabolites, precursors, and analogs. The grouping of principal
variants into referent groups was based on expertise from FDA
and NCHS. The referent groups table, which contains a list of
search terms and the principal variants included in each referent
drug category, is provided in the CSV file (https://ftp.cdc.gov/
pub/Health_Statistics/NCHS/Program_Code/oae/).
Analysis
Results are reported as numbers, percentages, or rates for
the deaths involving the referent drug. Deaths involving more
than one referent drug (e.g., a death involving both heroin and
cocaine) are counted in all relevant drug categories (e.g., the
same death is included in counts of heroin deaths and in counts
of cocaine deaths); therefore counts are not mutually exclusive.
Age-adjusted death rates are calculated using the direct method
and the 2000 standard U.S. population (12). Trends in age-
adjusted death rates are evaluated using the National Cancer
Institute’s Joinpoint Regression Program (version 4.6.0.0) (14).
Joinpoint software fitted weighted least-squares regression
models to the rates on the log transform scale. Allowing one
observed time point at each end and two for the middle line
segments, the Grid Search Algorithm searched for a maximum of
two joinpoints at an overall alpha level of 0.05 (15). Any mention
of an annual percent change in this report indicates a statistically
significant trend. Comparisons of rates between years were
tested for statistical significance using methods described
elsewhere (12).
Analyses of mentions of other drugs reported in addition
to the referent drug (concomitant drugs) were also conducted.
Only deaths with mention of at least two specific drugs (the
referent drug and at least one concomitant drug) are included in
this analysis. Alcohol, nicotine, and nondrug substances are not
included in the analysis.
The numbers and rates of drug-specific overdose deaths
shown in the tables and figures should be considered the
minimum number or rate for that referent drug category because
there could be additional deaths in which the drug was involved,
but the drug was not reported in the literal text on the death
certificate.
Assessing improvement in reporting on death
certificates
The ICD–10 multiple-cause codes T36–T50.8 provide
information on the types of drugs or drug classes involved in
the death. The percentage of deaths with an underlying-cause
code of X40–X44, X60–X64, X85, and Y10–Y14 that have a
multiple-cause code of T36–T50.8 is a measure of the specificity
of reporting of drugs or drug classes in drug overdose deaths.
This measure was used to assess possible changes in reporting
through the years of the study. The percentage of drug overdose
deaths with codes T36–T50.8 increased each year (75% in 2011,
76% in 2012, 78% in 2013, 81% in 2014, 83% in 2015, and 85%
in 2016).
This improvement in reporting of specific drugs and drug
classes during the study period could potentially influence the
observed trends in drug overdose deaths for specific drugs
(Figures 1–3). To assess the possible influence of improved
reporting, an adjustment analysis was conducted. In this
analysis, an adjustment factor was applied to each number and
age-adjusted rate for drug overdose deaths involving specific
drugs. The adjustment factor assumed that the specificity of
drug reporting remained constant from 2011 through 2016
at the 2016 rate (i.e., 85.4% of drug overdose deaths with an
ICD–10 multiple-cause code of T36–T50.8). A description of the
methodology and the results from the adjustment analysis are
provided in the Technical Notes.
Results
The number of drug overdose deaths per year increased
54%, from 41,340 deaths in 2011 to 63,632 deaths in 2016
(Table A). From the literal text analysis, the percentage of
drug overdose deaths mentioning at least one specific drug or
substance increased from 73% of the deaths in 2011 to 85% of
the deaths in 2016. The percentage of drug overdose deaths that
mentioned only a drug class but not a specific drug or substance
declined from 5.1% of deaths in 2011 to 2.5% in 2016. Review
of the literal text for these deaths indicated that the deaths that
mentioned only a drug class frequently involved either an opioid
or an opiate (ranging from 54% in 2015 to 60% in 2016). The
percentage of deaths that did not mention a specific drug or
substance or a drug class declined from 22% of drug overdose
deaths in 2011 to 13% in 2016.
Most frequently mentioned drugs
Table B shows the relative ranking of the top 15 drugs
involved in drug overdose deaths for each year from 2011
through 2016 among deaths that mentioned at least one specific
drug. The number of deaths for each drug should be interpreted
in light of the improvements in reporting as described in Table A,
and should be considered the minimum number for that drug
because there could be additional deaths in which the drug was
involved, but the drug was not reported in the literal text.
The top 15 drugs were identified based on the number of
drug overdose deaths per referent drug category. While the
ranking changed from year to year, the top 10 drugs involved
in overdose deaths remained consistent throughout the 6-year
period. The top 10 drugs belonged to three drug classes:
• Opioids: fentanyl, heroin, hydrocodone, methadone,
morphine, and oxycodone
• Benzodiazepines: alprazolam and diazepam
• Stimulants: cocaine and methamphetamine
The drugs that ranked 11–15 varied from year to year
and included such drugs as diphenhydramine, citalopram,
acetaminophen, carisoprodol, tramadol, oxymorphone, amitriptyline,
clonazepam, gabapentin, and amphetamine.
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4 National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018
Table A. Number and percentage of drug overdose deaths with mention of a specific drug, with mention of only a drug class, and
with no mention of a drug class or specific drug: United States, 2011-2016
2011 2012 2013 2014 2015 2016
Drug overdose deaths Number Percent Number Percent Number Percent Number Percent Number Percent Number Percent
All drug overdose deaths 00.0.2... .eeee. 41,340 100.0 41,502 100.0 43,982 100.0 47,055 100.0 52,404 100.0 63,632 100.0
Drug overdose deaths with mention of
at least one specific drug or
other substance... 728 30,923 74.5 33,640 76.5 37,631 80.0 43,141 82.3 54,137 85.1
Drug overdose deaths with mention of
a class only (no specific drug or
other substance) . . 51 2,093 «5.01918 441653851650 8.1 15865
Drug overdose deaths without
mention of a specific drug,
other substance, or class!.............. 9115 220 8486 «204 «84241927771 165 7,618 145 7,929 12.5
‘Category includes drug overdose deaths with mentions of substances not otherwise specified (NOS) (e.9., mention of “POLYPHARMACY” or “DRUG"”), uninformative text, and drug overdose
deaths with no mentions identified (e.g., text stating “OVERDOSE” with no mention of a drug).
NOTES: Drug overdose deaths are identified using /ntemational Classification ofDiseases, Tenth Revision (ICD-10) underlying cause-of-death codes X40-X44, X60-X64, X85, and Y10-Y14,
Percentages may not add to 100 due to rounding. The reporting of atleast one specific drug or drug class in the literal text, as identified using ICD-10 multiple cause-of-death codes
T36-T50.8, improved from 75% of drug overdose deaths in 2011 to 85% of drug overdose deaths in 2016.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text, 2011-2016.
For the top 15 drugs:
e Among drug overdose deaths that mentioned at least
one specific drug, oxycodone ranked first in 2011,
heroin from 2012 through 2015, and fentanyl in 2016.
e = In 2011 and 2012, fentanyl was mentioned in
approximately 1,600 drug overdose deaths each
year, but mentions increased in 2013 (1,919 deaths),
2014 (4,223 deaths), 2015 (8,251 deaths), and 2016
(18,335 deaths). In 2016, 29% of all drug overdose
deaths mentioned involvement of fentanyl.
e The number of drug overdose deaths involving heroin
increased threefold, from 4,571 deaths or 11% of all
drug overdose deaths in 2011 to 15,961 deaths or
25% of all drug overdose deaths in 2016.
e Throughout the study period, cocaine ranked second
or third among the top 15 drugs. From 2014 through
2016, the number of drug overdose deaths involving
cocaine nearly doubled from 5,892 to 11,316.
e The number of drug overdose deaths involving
methamphetamine increased 3.6-fold, from 1,887
deaths in 2011 to 6,762 deaths in 2016.
e The number of drug overdose deaths involving
methadone decreased from 4,545 deaths in 2011 to
3,493 deaths in 2016.
Age-adjusted rates for drug overdose deaths
involving the most frequently mentioned
drugs, 2011-2016
Trends from 2011 through 2016 in the age-adjusted rates
of drug overdose deaths involving the 10 most frequently
mentioned drugs are shown in Figures 1-3. Improvements in
reporting should be considered when interpreting these trends
(see Technical Notes). As a reference, from 2011 through 2016,
‘the age-adjusted rate of all drug overdose deaths, whether or not
aspecific drug was mentioned, increased from 13.2 per 100,000
to 19.8, an average increase of 9% per year.
e From 2011 through 2016, the age-adjusted rate of drug
overdose deaths involving heroin more than tripled from
1.5 per 100,000 population to 5.1. The rate increased on
average by about 34% per year from 2011 through 2014,
and by about 20% per year from 2014 through 2016
(Figure 1, Table).
N
1
@
T
a
T
s
T
N
T
Deaths
per
100,000
standard
population
oo
T
Hydrocodone
1 1 1 1
°
2011 2012 2013 2014 2015 2016
“Significant increasing trend for 2013-2016, p < 0.05,
Significant increasing trend for 2011-2016 with different rates of change over time,
p<0.05,
Significant decreasing trend for 2011-2014, p < 0.05.
«Significant increasing trend for 2011-2015, p < 0.05,
NOTES: Drug overdose deaths are identified using international Classification of
Diseases, Tenth Revision underlying cause-of-death codes X40-X44, X60-X64, X85, and
Y10-¥14" Deaths may involve other drugs in additionto the referent drug (ie., the one
listed). Deaths involving more than one drug (e.9., a death involving both heroin and
cocaine) are counted in both totals. Caution should be used when comparing numbers
across years. The reporting of at least one specific drug in the literal text improved from.
73% of drug overdose deaths in 2011 to 85% of drug overdose deaths in 2016.
‘SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death
certificate literal text, 2011-2016,
Figure 1. Age-adjusted rates for drug overdose deaths
involving selected opioids, 2011-2016
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5
Table B. Top 15 drugs involved in drug overdose deaths: United States, 2011–2016
Rank1
2011 (n = 41,340) 2012 (n = 41,502) 2013 (n = 43,982)
Referent drug
Number of
deaths2
Percent
of deaths3 Referent drug
Number of
deaths2
Percent
of deaths3 Referent drug
Number of
deaths2
Percent
of deaths3
1 Oxycodone . . . . . . . . . . . . . . . . . 5,587 13.5 Heroin . . . . . . . . . . . . . . . . . . . . 6,155 14.8 Heroin . . . . . . . . . . . . . . . . . . . . 8,418 19.1
2 Cocaine . . . . . . . . . . . . . . . . . . . 5,070 12.3 Oxycodone . . . . . . . . . . . . . . . . . 5,178 12.5 Cocaine . . . . . . . . . . . . . . . . . . . 5,319 12.1
3 Heroin . . . . . . . . . . . . . . . . . . . . 4,571 11.1 Cocaine . . . . . . . . . . . . . . . . . . . 4,780 11.5 Oxycodone . . . . . . . . . . . . . . . . . 4,967 11.3
4 Methadone . . . . . . . . . . . . . . . . . 4,545 11.0 Methadone . . . . . . . . . . . . . . . . . 4,087 9.8 Morphine . . . . . . . . . . . . . . . . . . 3,772 8.6
5 Alprazolam . . . . . . . . . . . . . . . . . 4,066 9.8 Alprazolam . . . . . . . . . . . . . . . . . 3,803 9.2 Alprazolam . . . . . . . . . . . . . . . . . 3,724 8.5
6 Morphine . . . . . . . . . . . . . . . . . . 3,290 8.0 Morphine . . . . . . . . . . . . . . . . . . 3,513 8.5 Methadone . . . . . . . . . . . . . . . . . 3,700 8.4
7 Hydrocodone . . . . . . . . . . . . . . . 3,206 7.8 Hydrocodone . . . . . . . . . . . . . . . 3,037 7.3 Methamphetamine . . . . . . . . . . . 3,194 7.3
8 Methamphetamine . . . . . . . . . . . 1,887 4.6 Methamphetamine . . . . . . . . . . . 2,267 5.5 Hydrocodone . . . . . . . . . . . . . . . 3,113 7.1
9 Diazepam . . . . . . . . . . . . . . . . . . 1,698 4.1 Fentanyl . . . . . . . . . . . . . . . . . . . 1,615 3.9 Fentanyl . . . . . . . . . . . . . . . . . . . 1,919 4.4
10 Fentanyl . . . . . . . . . . . . . . . . . . . 1,662 4.0 Diazepam . . . . . . . . . . . . . . . . . . 1,577 3.8 Diazepam . . . . . . . . . . . . . . . . . . 1,618 3.7
11 Diphenhydramine . . . . . . . . . . . . 1,226 3.0 Diphenhydramine . . . . . . . . . . . . 1,300 3.1 Diphenhydramine . . . . . . . . . . . . 1,360 3.1
12 Oxymorphone . . . . . . . . . . . . . . 1,190 2.9 Citalopram . . . . . . . . . . . . . . . . . 1,042 2.5 Tramadol . . . . . . . . . . . . . . . . . . 1,009 2.3
13 Citalopram . . . . . . . . . . . . . . . . . 1,043 2.5 Tramadol . . . . . . . . . . . . . . . . . . 935 2.3 Clonazepam . . . . . . . . . . . . . . . . 946 2.2
14 Acetaminophen . . . . . . . . . . . . . 879 2.1 Oxymorphone . . . . . . . . . . . . . . 866 2.1 Citalopram . . . . . . . . . . . . . . . . . 914 2.1
15 Tramadol . . . . . . . . . . . . . . . . . . 849 2.1 Amitriptyline. . . . . . . . . . . . . . . . 835 2.0 Amitriptyline. . . . . . . . . . . . . . . . 815 1.9
Rank1
2014 (n = 47,055) 2015 (n = 52,404) 2016 (n = 63,632)
Referent drug
Number of
deaths2
Percent
of deaths3 Referent drug
Number of
deaths2
Percent
of deaths3 Referent drug
Number of
deaths2
Percent
of deaths3
1 Heroin . . . . . . . . . . . . . . . . . . . . 10,882 23.1 Heroin . . . . . . . . . . . . . . . . . . . . 13,318 25.4 Fentanyl . . . . . . . . . . . . . . . . . . . 18,335 28.8
2 Cocaine . . . . . . . . . . . . . . . . . . . 5,892 12.5 Fentanyl . . . . . . . . . . . . . . . . . . . 8,251 15.7 Heroin . . . . . . . . . . . . . . . . . . . . 15,961 25.1
3 Oxycodone . . . . . . . . . . . . . . . . . 5,431 11.5 Cocaine . . . . . . . . . . . . . . . . . . . 7,324 14.0 Cocaine . . . . . . . . . . . . . . . . . . . 11,316 17.8
4 Alprazolam . . . . . . . . . . . . . . . . . 4,237 9.0 Oxycodone . . . . . . . . . . . . . . . . . 5,792 11.1 Methamphetamine . . . . . . . . . . . 6,762 10.6
5 Fentanyl . . . . . . . . . . . . . . . . . . . 4,223 9.0 Methamphetamine . . . . . . . . . . . 5,092 9.7 Alprazolam . . . . . . . . . . . . . . . . . 6,209 9.8
6 Morphine . . . . . . . . . . . . . . . . . . 4,024 8.6 Alprazolam . . . . . . . . . . . . . . . . . 4,801 9.2 Oxycodone . . . . . . . . . . . . . . . . . 6,199 9.7
7 Methamphetamine . . . . . . . . . . . 3,747 8.0 Morphine . . . . . . . . . . . . . . . . . . 4,226 8.1 Morphine . . . . . . . . . . . . . . . . . . 5,014 7.9
8 Methadone . . . . . . . . . . . . . . . . . 3,498 7.4 Methadone . . . . . . . . . . . . . . . . . 3,376 6.4 Methadone . . . . . . . . . . . . . . . . . 3,493 5.5
9 Hydrocodone . . . . . . . . . . . . . . . 3,299 7.0 Hydrocodone . . . . . . . . . . . . . . . 3,051 5.8 Hydrocodone . . . . . . . . . . . . . . . 3,199 5.0
10 Diazepam . . . . . . . . . . . . . . . . . . 1,748 3.7 Diphenhydramine . . . . . . . . . . . . 1,798 3.4 Diazepam . . . . . . . . . . . . . . . . . . 2,022 3.2
11 Diphenhydramine . . . . . . . . . . . . 1,614 3.4 Diazepam . . . . . . . . . . . . . . . . . . 1,796 3.4 Diphenhydramine . . . . . . . . . . . . 2,008 3.2
12 Tramadol . . . . . . . . . . . . . . . . . . 1,175 2.5 Clonazepam . . . . . . . . . . . . . . . . 1,328 2.5 Clonazepam . . . . . . . . . . . . . . . . 1,656 2.6
13 Clonazepam . . . . . . . . . . . . . . . . 1,139 2.4 Gabapentin . . . . . . . . . . . . . . . . . 1,222 2.3 Gabapentin . . . . . . . . . . . . . . . . . 1,546 2.4
14 Citalopram . . . . . . . . . . . . . . . . . 1,014 2.2 Tramadol . . . . . . . . . . . . . . . . . . 1,177 2.2 Tramadol . . . . . . . . . . . . . . . . . . 1,250 2.0
15 Oxymorphone . . . . . . . . . . . . . . 909 1.9 Oxymorphone . . . . . . . . . . . . . . 1,006 1.9 Amphetamine . . . . . . . . . . . . . . . 1,193 1.9
1Ranks were not tested for statistical significance.
2Number of drug overdose deaths involving the referent drug.
3Percentage of drug overdose deaths involving the referent drug.
NOTES: Drug overdose deaths are identified using International Classification of Diseases, Tenth Revision (ICD–10) underlying cause-of-death codes X40–X44, X60–X64, X85, and Y10–Y14. Deaths may involve other drugs in addition to the referent
drug (i.e., the one listed). Deaths involving more than one drug (e.g., a death involving both heroin and cocaine) are counted in both totals. Caution should be used when comparing numbers across years. The reporting of at least one specific drug or
drug class in the literal text, as identified using ICD–10 multiple cause-of-death codes T36–T50.8, improved from 75% of drug overdose deaths in 2011 to 85% of drug overdose deaths in 2016.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text, 2011–2016.
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6 National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018
407
35
30
25h
20
15 Alprazolam
10-
Deaths
per
100,000
standard
population
Diazepam
CC
00 L L L L L L
2011 2012 2013 2014 2015 2016
NOTES: Drug overdose deaths are identified using international Classification of
Diseases, Tenth Revision underlying cause-of-death codes X40-X44, X60-X64, X85, and.
‘Y10-Y14. Deaths may involve other drugs in addition to the referent drug (ie., the one
listed). Deaths involving more than one drug (e.9., a death involving both heroin and
cocaine) are counted in both totals. Caution should be used when comparing numbers
across years. The reporting of at least one specific drug in the literal text improved from
73% of drug overdose deaths in 2011 to 85% of drug overdose deaths in 2016.
‘SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death
certificate literal text, 2011-2016.
s
oS
1
wo
a
T
e
o
T
N
a
T
a
T
o
T
Methamphetamine"
Deaths
per
100,000
standard
population
N
S
T
2
a
T
00 1 1 1 1 1 1
2011 2012 2013-2014 2015-2016
“Significant increasing trend for 2011-2016, p < 0.05.
NOTES: Drug overdose deaths are identified using international Classification of
Diseases, Tenth Revision underlying cause-of-death codes X40-X44, X60-X64, X85, and.
‘Y10-Y14. Deaths may involve other drugs in additionto the referent drug (ie., the one
listed). Deaths involving more than one drug (e.9., a death involving both heroin and
cocaine) are counted in both totals. Caution should be used when comparing numbers
across years. The reporting of at least one specific drug in the literal text improved from
73% of drug overdose deaths in 2011 to 85% of drug overdose deaths in 2016.
‘SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death
certificate literal text, 2011-2016.
Figure 2. Age-adjusted rates for drug overdose deaths
involving selected benzodiazepines, 2011-2016
e From 2011 through 2013, there was no statistical change in
the age-adjusted rate of drug overdose deaths involving
fentanyl. From 2013 through 2016, the rate increased on
average by about 113% per year, from 0.6 per 100,000
population in 2013, to 1.3 in 2014, 2.6 in 2015, and 5.9 in
2016.
The age-adjusted rate of drug overdose deaths involving
morphine increased from 1.0 per 100,000 population in
2011 to 1.5 in 2016. The rate increased on average by about
6% per year from 2011 through 2015. Between 2015 and
2016, the rate changed 18%, however, this trend was not
statistically significant.
The age-adjusted rate of drug overdose deaths involving
methadone decreased from 1.4 per 100,000 population in
2011 to 1.1 in 2016. The rate decreased on average by about
10% per year from 2011 through 2014. From 2014 through
2016, there was no significant change in the rate.
From 2011 through 2016, there was no significant change
in the age-adjusted death rate for drug overdose deaths
involving hydrocodone.
The age-adjusted rate of drug overdose deaths involving
oxycodone decreased from 1.8 per 100,000 population in
2011 to 1.6 in 2013, then increased to 1.9 in 2016; however,
these decreasing and increasing trends were not statistically
significant.
The age-adjusted rate of drug overdose deaths involving
alprazolam decreased from 1.3 per 100,000 population in
2011 to 1.2 in 2013, then increased to 2.0 in 2016; however,
these decreasing and increasing trends were not statistically
significant (Figure 2, Table).
Figure 3. Age-adjusted rates for drug overdose deaths
involving selected stimulants, 2011-2016
e From 2011 through 2016, there was no significant change
in the age-adjusted rate for drug overdose deaths involving
diazepam.
The age-adjusted rate of drug overdose deaths involving
cocaine increased from 1.6 per 100,000 population in 2011
to 3.6 in 2016. The rate increased on average by about 18%
per year (Figure 3, Table).
The age-adjusted rate of drug overdose deaths involving
methamphetamine more than tripled from 0.6 per 100,000
population in 2011 to 2.1 in 2016. The rate increased on
average by about 29% per year.
In the adjustment analysis, the findings for the trends in
rates based on observed and adjusted numbers were,
in general, the same for fentanyl, oxycodone, diazepam,
cocaine, and methamphetamine (see Technical Notes). For
heroin, the inflection point in 2014 was no longer found,
resulting in a percent change in the rate of about 24% per
year from 2011 through 2016. For morphine, the inflection
point in 2015 was no longer found, resulting in a percent
change in the rate of about 5% per year from 2011 through
2016. For methadone, rates decreased by about 12% per
year from 2011 through 2014, and by about 3% from 2014
through 2016. For hydrocodone, there was a significant
decline in the age-adjusted rates of about 4% per year from
2011 through 2016. For alprazolam, the inflection point in
2013 was no longer found, and as with the observed values,
the increasing trend from 2011 through 2016 was not
statistically significant.
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National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018 7
Drug overdose deaths in 2016 involving
multiple drugs
Table C shows the percentage of drug overdose deaths with
concomitant involvement of other drugs for the top 10 drugs
involved in drug overdose deaths in 2016. The percentage of
deaths with concomitant involvement of other drugs varied by
drug. For example, almost all drug overdose deaths involving
alprazolam or diazepam (96%) mentioned involvement of other
drugs. In contrast, 50% of the drug overdose deaths involving
methamphetamine, and 69% of the drug overdose deaths
involving fentanyl mentioned involvement of one or more other
specific drugs.
Table D shows the most frequent concomitant drug
mentions for each of the top 10 drugs involved in drug overdose
deaths in 2016.
• Two in five overdose deaths involving cocaine also
mentioned fentanyl.
• Nearly one-third of drug overdose deaths involving fentanyl
also mentioned heroin (32%).
• Alprazolam was mentioned in 26% of the overdose deaths
involving hydrocodone, 22% of the deaths involving
methadone, and 25% of the deaths involving oxycodone.
• More than one-third of the overdose deaths involving
cocaine also mentioned heroin (34%).
• More than 20% of the overdose deaths involving
methamphetamine also mentioned heroin.
Most frequently mentioned drugs involved
in drug overdose deaths in 2016, by intent of
death
Table E shows the top 10 drugs involved in drug overdose
deaths in 2016 by intent of death, for deaths in which at least
one specific drug was identified. Results are shown for
unintentional drug overdose deaths (ICD–10 underlying-cause
codes X40–X44), suicides by drug overdose (ICD–10 underlying-
cause codes X60–X64), and drug overdose deaths for which the
intent could not be determined (undetermined intent; [ICD–10
underlying-cause codes Y10–Y14]). The results for 110 deaths
with an intent of homicide (ICD–10 underlying-cause code X85)
are not shown due to small numbers.
In 2016, unintentional drug overdose deaths most frequently
mentioned fentanyl, heroin, and cocaine, while suicides
by drug overdose most frequently mentioned oxycodone,
diphenhydramine, hydrocodone, and alprazolam. Methadone
ranked in the top 10 for unintentional and undetermined intent
deaths, but not among suicides by drug overdose. Quetiapine,
tramadol, bupropion, and zolpidem ranked in the top 10 for
suicides by drug overdose, but not for unintentional drug
overdose deaths and overdose deaths of undetermined intent.
Discussion
Findings for specific drugs
From 2011 through 2016, the number of drug overdose
deaths increased by 54%, from 41,340 deaths in 2011 to 63,632
deaths in 2016. The most frequently mentioned drugs involved
in these deaths were the opioids heroin, oxycodone, methadone,
morphine, hydrocodone, and fentanyl; the benzodiazepines
alprazolam and diazepam; and the stimulants cocaine and
methamphetamine.
Among drug overdose deaths that mentioned at least one
specific drug, oxycodone ranked first in 2011, heroin ranked
first from 2012 through 2015, and fentanyl ranked first in 2016.
Cocaine ranked second or third throughout the study period.
An analysis of trends among the most frequently mentioned
drugs showed that, for several drugs, the age-adjusted rate of
Table C. Number and percentage of deaths with concomitant drug involvement for drug overdose deaths involving the top 10 drugs:
United States, 2016
Referent drug
Number of drug overdose deaths
involving the referent drug
Number of drug overdose deaths
involving the referent drug and
one or more concomitant drugs
Percentage of drug overdose deaths
involving the referent drug and
one or more concomitant drugs
Opioids
Fentanyl . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18,335 12,694 69.2
Heroin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15,961 11,248 70.5
Hydrocodone . . . . . . . . . . . . . . . . . . . . . . . . . . . 3,199 2,743 85.7
Methadone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3,493 2,551 73.0
Morphine . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5,014 4,175 83.3
Oxycodone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6,199 5,027 81.1
Benzodiazepines
Alprazolam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6,209 5,970 96.2
Diazepam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2,022 1,951 96.5
Stimulants
Cocaine . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11,316 8,363 73.9
Methamphetamine . . . . . . . . . . . . . . . . . . . . . . . 6,762 3,370 49.8
NOTES: Drug overdose deaths are identified using International Classification of Diseases, Tenth Revision underlying cause-of-death codes X40–X44, X60–X64, X85, and Y10–Y14. Only
deaths with at least one specific drug identified are included in the analysis.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text, 2016.
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8 National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018
Table E. Top 10 drugs involved in drug overdose deaths, by intent of death: United States, 2016
Rank1
Unintentional (n = 54,793) Suicide (n = 5,086) Undetermined (n = 3,643)
Referent drug
Number of
deaths2
Percent of
deaths3 Referent drug
Number of
deaths2
Percent of
deaths3 Referent drug
Number of
deaths2
Percent of
deaths3
1 Fentanyl . . . . . . . . . . . . . . 16,981 31.0 Oxycodone . . . . . . . . . . . . 648 12.7 Fentanyl . . . . . . . . . . . . . . 1,185 32.5
2 Heroin . . . . . . . . . . . . . . . 15,075 27.5 Diphenhydramine . . . . . . . 576 11.3 Heroin . . . . . . . . . . . . . . . 766 21.0
3 Cocaine . . . . . . . . . . . . . . 10,618 19.4 Hydrocodone . . . . . . . . . . 472 9.3 Morphine . . . . . . . . . . . . . 619 17.0
4 Methamphetamine . . . . . . 6,448 11.8 Alprazolam . . . . . . . . . . . . 468 9.2 Cocaine . . . . . . . . . . . . . . 579 15.9
5 Alprazolam . . . . . . . . . . . . 5,510 10.1 Acetaminophen . . . . . . . . 343 6.7 Oxycodone . . . . . . . . . . . . 322 8.8
6 Oxycodone . . . . . . . . . . . . 5,225 9.5 Quetiapine . . . . . . . . . . . . 297 5.8 Methadone . . . . . . . . . . . . 264 7.2
7 Morphine . . . . . . . . . . . . . 4,122 7.5 Morphine . . . . . . . . . . . . . 268 5.3 Alprazolam . . . . . . . . . . . . 225 6.2
8 Methadone . . . . . . . . . . . . 3,110 5.7 Tramadol . . . . . . . . . . . . . 266 5.2 Methamphetamine . . . . . . 195 5.4
9 Hydrocodone . . . . . . . . . . 2,556 4.7 Bupropion . . . . . . . . . . . . 264 5.2 Hydrocodone . . . . . . . . . . 169 4.6
10 Diazepam . . . . . . . . . . . . . 1,723 3.1 Zolpidem . . . . . . . . . . . . . 251 4.9 Diphenhydramine . . . . . . . 152 4.2
1Ranks were not tested for statistical significance.
2Number of drug overdose deaths involving the referent drug.
3Percentage of drug overdose deaths involving the referent drug.
NOTES: Drug overdose deaths are identified using International Classification of Diseases, Tenth Revision underlying cause-of-death codes X40–X44 (unintentional), X60–X64 (suicide), and
Y10–Y14 (undetermined). Only deaths with at least one specific drug identified are included in the analysis. The results for 110 deaths with an intent of homicide (X85) are not shown due to
small numbers. Deaths may involve other drugs in addition to the referent drug (i.e., the one listed). Deaths involving more than one drug (e.g., a death involving both heroin and cocaine) are
counted in both totals.
SOURCE: NCHS National Vital Statistics System, Mortality files linked with death certificate literal text, 2016.
Table D. Most frequent concomitant drugs for drug overdose deaths involving the top 10 drugs: United States, 2016
Referent drug
Number of drug
overdose deaths
involving the
referent drug
Most frequent
concomitant drug
Second most frequent
concomitant drug
Third most frequent
concomitant drug
Concomitant
drug
Number and
percentage1 of
deaths involving
both drugs
Concomitant
drug
Number and
percentage1 of
deaths involving
both drugs
Concomitant
drug
Number and
percentage1 of
deaths involving
both drugs
Opioids
Fentanyl . . . . . . . . . . . . . . . . . . . . . 18,335 Heroin 5,915 (32.3) Cocaine 4,598 (25.1) Alprazolam 1,760 (9.6)
Heroin . . . . . . . . . . . . . . . . . . . . . . 15,961 Fentanyl 5,915 (37.1) Cocaine 3,804 (23.8) Alprazolam 1,668 (10.5)
Hydrocodone . . . . . . . . . . . . . . . . . 3,199 Alprazolam 822 (25.7) Oxycodone 551 (17.2) Fentanyl 478 (14.9)
Methadone . . . . . . . . . . . . . . . . . . . 3,493 Alprazolam 751 (21.5) Fentanyl 528 (15.1) Heroin 483 (13.8)
Morphine . . . . . . . . . . . . . . . . . . . . 5,014 Fentanyl 1,612 (32.1) Cocaine 846 (16.9) Heroin 687 (13.7)
Oxycodone . . . . . . . . . . . . . . . . . . . 6,199 Alprazolam 1,571 (25.3) Fentanyl 1,150 (18.6) Morphine 668 (10.8)
Benzodiazepines
Alprazolam . . . . . . . . . . . . . . . . . . . 6,209 Fentanyl 1,760 (28.3) Heroin 1,668 (26.9) Oxycodone 1,571 (25.3)
Diazepam . . . . . . . . . . . . . . . . . . . . 2,022 Oxycodone 576 (28.5) Fentanyl 502 (24.8) Heroin 404 (20.0)
Stimulants
Cocaine . . . . . . . . . . . . . . . . . . . . . 11,316 Fentanyl 4,598 (40.6) Heroin 3,804 (33.6) Alprazolam 1,031 (9.1)
Methamphetamine . . . . . . . . . . . . . 6,762 Heroin 1,477 (21.8) Fentanyl 753 (11.1) Cocaine 562 (8.3)
1Percentage of drug overdose deaths involving the referent drug that also involved the concomitant drug. Deaths may involve more than one concomitant drug in addition to the referent drug.
NOTES: Drug overdose deaths are identified using International Classification of Diseases, Tenth Revision underlying cause-of-death codes X40–X44, X60–X64, X85, and Y10–Y14. Only
deaths with at least one specific drug identified are included in the analysis.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text, 2016.
drug overdose deaths increased considerably within a relatively
short period. From 2011 through 2016, the rate of drug overdose
deaths involving heroin more than tripled, as did the rate of drug
overdose deaths involving methamphetamine. The rate of drug
overdose deaths involving fentanyl and fentanyl analogs doubled
each year from 2013 through 2016, from 0.6 per 100,000 in 2013
to 1.3 in 2014, 2.6 in 2015, and 5.9 in 2016. Among the drugs
discussed in this report, only methadone showed a decreasing
drug overdose death rate, from 1.4 per 100,000 in 2011 to 1.1
in 2016.
Results from the literal text analysis highlight the
concomitant occurrence of more than one drug in many drug
overdose deaths. For the top 10 drugs involved in drug overdose
deaths in 2016, the proportion of deaths involving both the
referent drug and at least one other concomitant drug ranged
from 50% for methamphetamine to 96% for alprazolam or
diazepam. Approximately 70% of drug overdose deaths involving
fentanyl or heroin—the top two drugs involved in drug overdose
deaths in 2016—involved at least one other specific drug.
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National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018 9
involving hydrocodone showed a significant decline of about 4%
per year from 2011 through 2016.
Methods based on literal text analysis are dependent on the
quality and completeness of the literal text, which may vary from
jurisdiction to jurisdiction due to variation in death investigation
and reporting practices or other differences in the medicolegal
death investigation systems across the United States (16,17).
Issues that contribute to variation in literal text information on
drug overdose deaths have been discussed in detail elsewhere
(11,18), and briefly, include certain factors.
Variation in death investigation practice and reporting—
This includes whether or not toxicological laboratory testing
is performed to determine the type(s) of drugs present. The
substances tested for and the circumstances under which the
tests are performed may vary by jurisdiction, decedent, and over
time.
Interpretation of toxicology results—Interpretation of
findings depends on which tests are ordered, the characteristics
of the causative agent(s), the characteristics of the metabolites,
and other evidence gathered during the investigation and
examination.
Attribution to a specific drug—Some drugs have the
same metabolites or are metabolites of other drugs, potentially
resulting in misattribution of the specific drugs involved in the
death. For example, mentions of morphine may actually refer
to involvement of heroin because morphine is a metabolite of
heroin (9). This could potentially result in underestimation of
the number of deaths involving heroin and overestimation of the
number of deaths involving morphine.
Determination of which drugs to report on the death
certificate—Some medical certifiers focus on a single lethal drug
rather than listing multiple drugs involved in the death, while
others may list multiple drugs because they believe the drugs to
be of equal lethality or that the interaction of all drugs mentioned
is important. Some certifiers may not want to impose an order
when listing the drugs that were present. Others have noted that
space limitations in the software programs they use to complete
electronic death registration limit their ability to include all drugs
that contributed to the death.
These and other factors may contribute to the variation in
the completeness and accuracy of the information on the death
certificate about the specific drugs involved in the death. The
literal text analysis is dependent on the quality of the information
available. Therefore, the results presented in this report should
be considered the minimum number or rate for that specific drug
because there could be additional deaths in which the drug was
involved, but the drug was not reported in the literal text.
Finally, it is possible that drugs rarely seen in drug overdose
deaths were not included in the search term list used in this
study, despite the multiple avenues taken to develop the list of
search terms (7). This also could result in underestimation of the
number of deaths involving a specific drug.
The 10 most frequently mentioned drugs were often
found in combination with each other. Drug combinations
often involved drugs of different drug classes. For example,
the opioid fentanyl and the stimulant cocaine were mentioned
concomitantly in nearly 4,600 deaths. The opioid oxycodone and
the benzodiazepine alprazolam were mentioned concomitantly in
more than 1,500 deaths. In some instances, the most frequently
mentioned concomitant drug was in the same drug class as the
referent drug. For example, the opioids fentanyl and heroin were
both mentioned in approximately 5,900 deaths. While the literal
text can be used to identify the mention of the two drugs (fentanyl
and heroin), the details to distinguish whether the heroin and
fentanyl were taken as one (i.e., heroin laced with fentanyl) or as
two separate drugs are often not available.
The drugs most frequently mentioned in the literal text
varied by the intent of the drug overdose death. In 2016,
unintentional drug overdose deaths most frequently mentioned
fentanyl, heroin, and cocaine, while suicides by drug overdose
more frequently mentioned oxycodone, diphenhydramine,
hydrocodone, and alprazolam.
Data considerations and study limitations
This report used analysis of the literal text on death
certificates to identify the drugs involved in overdose deaths (7).
Software programs search the literal text for mentions of drugs
and for terms that provide context about the involvement of the
drug in the death. As shown in Table C, drug overdose deaths
frequently involve multiple drugs. For deaths in which multiple
drugs are involved, whether the death was caused by just one of
the drugs present or was caused by a combination of some or all
of the drugs present cannot be determined from the literal text
analysis. This limitation in identifying the specific contribution of
any given drug to the death should be considered when reviewing
the findings in this report.
Reporting of deaths with at least one specific drug in the
death certificate literal text improved from 73% of drug overdose
deaths in 2011 to 85% in 2016. While improved reporting
enhances the quality of the data, it also creates complexity in
interpreting the trends and rankings observed. The findings in
this report should be considered in light of the improvements
in reporting. For example, some of the observed increase from
2011 through 2016 in drug overdose deaths involving the top
10 drugs is likely attributable to improvements in reporting.
However, it is unlikely that the large increases seen for some
drugs such as fentanyl, heroin, cocaine, and methamphetamine
(i.e., drugs with an annual percent increase in mortality rates of
18% or greater) are due solely to improvements in reporting.
True increases in the number of deaths involving these drugs
are likely to have occurred. Similarly, decreases in rates such as
those seen for drug overdose deaths involving methadone are
likely to be, at least in part, due to a true decrease. It is also
possible that the improvements in reporting could obscure real
decreases. For example, using observed values, there was no
statistically significant change in the age-adjusted rate of drug
overdose deaths involving hydrocodone from 2011 through
2016. However, after adjustment for improved reporting (see
Technical Notes), the age-adjusted rate of drug overdose deaths
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10 National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018
Conclusions
Literal text analysis can be used to extract key information
from death certificates to improve national monitoring of drug
overdose deaths. This report identifies the specific drugs most
frequently mentioned in drug overdose deaths from 2011 through
2016, and shows that the most frequent drugs mentioned varied
over time and by intent of death (i.e., unintentional drug overdose,
suicide by drug overdose, and overdose death of undetermined
intent). Results from the literal text analysis also confirm that
many drug overdose deaths involve multiple drugs.
With slight modification, the methods used in this report can
be used to identify deaths involving newly approved prescription
drugs and new substances of abuse. Periodic updating of search
terms and text search capabilities is essential for the ongoing
surveillance and monitoring of emerging trends in drug overdose
deaths using literal text analysis. In addition, this report highlights
the critical importance of reporting the specific drugs involved in
drug overdose deaths in the literal text on death certificates.
References
1. Hedegaard H, Warner M, Miniño AM. Drug overdose deaths in the
United States, 1999–2016. NCHS Data Brief, no 294. Hyattsville,
MD: National Center for Health Statistics. 2017. Available from:
https://www.cdc.gov/nchs/data/databriefs/db294.pdf.
2. Seth P, Scholl L, Rudd RA, Bacon S. Overdose deaths involving
opioids, cocaine, and psychostimulants—United States, 2015–2016.
MMWR Morb Mortal Wkly Rep 67(12):349–58. 2018. Available
from: https://www.cdc.gov/mmwr/volumes/67/wr/mm6712a1.htm.
3. Jones CM, Einstein EB, Compton WM. Changes in synthetic
opioid involvement in drug overdose deaths in the United States,
2010–2016. JAMA 319(17):1819–21. 2018. Available from: https://
jamanetwork.com/journals/jama/fullarticle/2679931?resultClick=1.
4. Rudd RA, Seth P, David F, Scholl L. Increases in drug and opioid-
involved overdose deaths—United States, 2010–2015. MMWR
Morb Mortal Wkly Rep 65(50–51):1445–52. 2016. Available from:
https://www.cdc.gov/mmwr/volumes/65/wr/mm655051e1.htm.
5. Jones CM, Baldwin GT, Compton WM. Recent increases in
cocaine-related overdose deaths and the role of opioids. Am J
Public Health 107(3):430–2. 2017. Available from: http://ajph.
aphapublications.org/doi/pdf/10.2105/AJPH.2016.303627.
6. World Health Organization. International statistical classification
of diseases and related health problems, Tenth revision (ICD–10).
1st ed. Geneva, Switzerland. 1992.
7. Trinidad JP, Warner M, Bastian BA, Miniño AM, Hedegaard H.
Using literal text from the death certificate to enhance mortality
statistics: Characterizing drug involvement in deaths. National
Vital Statistics Reports; vol 65 no 9. Hyattsville, MD: National
Center for Health Statistics. 2016. Available from: https://www.
cdc.gov/nchs/data/nvsr/nvsr65/nvsr65_09.pdf.
8. National Center for Health Statistics. Medical examiners' and
coroners' handbook on death registration and fetal death
reporting. Hyattsville, MD: National Center for Health Statistics.
2003. Available from: https://www.cdc.gov/nchs/data/misc/hb_
me.pdf.
9. Davis GG. National Association of Medical Examiners position
paper: Recommendations for the investigation, diagnosis, and
certification of deaths related to opioid drugs. Acad Forensic
Pathol 3(1):77–83. 2013.
10. National Center for Health Statistics. 2003 revision of the U.S.
Standard Certificate of Death. Available from: https://www.cdc.
gov/nchs/data/dvs/death11-03final-acc.pdf.
11. Warner M, Trinidad JP, Bastian BA, Miniño AM, Hedegaard H.
Drugs most frequently involved in drug overdose deaths:
United States, 2010–2014. National Vital Statistics Reports;
vol 65 no 10. Hyattsville, MD: National Center for Health Statistics.
2016. Available from: https://www.cdc.gov/nchs/data/nvsr/nvsr65/
nvsr65_10.pdf.
12. Murphy SL, Xu JQ, Kochanek KD, Curtin SC, Arias E. Deaths: Final
data for 2015. National Vital Statistics Reports; vol 66 no 6.
Hyattsville, MD: National Center for Health Statistics. 2017. Available
from: https://www.cdc.gov/nchs/data/nvsr/nvsr66/nvsr66_06.pdf.
13. Chen LH, Hedegaard H, Warner M. Drug-poisoning deaths
involving opioid analgesics: United States, 1999–2011. NCHS
Data Brief, no 166. Hyattsville, MD: National Center for Health
Statistics. 2014. Available from: https://www.cdc.gov/nchs/data/
databriefs/db166.pdf.
14. National Cancer Institute. Joinpoint Regression Program
(Version 4.6.0.0) [computer software]. 2018.
15. Ingram DD, Malec DJ, Makuc DM, Kruszon-Moran D, Gindi RM,
Albert M, et al. National Center for Health Statistics Guidelines
for Analysis of Trends. National Center for Health Statistics. Vital
Health Stat 2(179). 2018. Available from: https://www.cdc.gov/
nchs/data/series/sr_02/sr02_179.pdf.
16. National Research Council. Strengthening forensic science in
the United States: A path forward. Washington, DC: National
Academies Press. 2009.
17. Harruff RC, Couper FJ, Banta-Green CJ. Tracking the opioid drug
overdose epidemic in King County, Washington using an improved
methodology for certifying heroin related deaths. Acad Forensic
Pathol 5(3):499–506. 2015.
18. Council of State and Territorial Epidemiologists. Recommendations
and lessons learned for improved reporting of drug overdose
deaths on death certificates. 2016. Available from: https://c.
ymcdn.com/sites/www.cste.org/resource/resmgr/PDFs/
PDFs2/4_25_2016_FINAL-Drug_Overdos.pdf.
Detailed Table
Age-adjusted rates for drug overdose deaths involving selected
opioids, benzodiazepines, and stimulants: United States,
2011–2016 11
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National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018 11
Table. Age-adjusted rates for drug overdose deaths involving selected opioids, benzodiazepines, and stimulants: United States,
2011–2016
Referent drug 2011 2012 2013 2014 2015 2016
Opioids
Fentanyl . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.5 0.5 0.6 1.3 2.6 5.9
Heroin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.5 2.0 2.7 3.5 4.3 5.1
Hydrocodone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.0 1.0 1.0 1.0 0.9 1.0
Methadone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.4 1.3 1.2 1.1 1.1 1.1
Morphine . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.0 1.1 1.2 1.2 1.3 1.5
Oxycodone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.8 1.7 1.6 1.7 1.8 1.9
Benzodiazepines
Alprazolam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.3 1.2 1.2 1.3 1.5 2.0
Diazepam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.5 0.5 0.5 0.5 0.5 0.6
Stimulants
Cocaine . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.6 1.5 1.7 1.8 2.3 3.6
Methamphetamine . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.6 0.7 1.0 1.2 1.6 2.1
NOTES: Drug overdose deaths are identified using International Classification of Diseases, Tenth Revision (ICD–10) underlying cause-of-death codes X40–X44, X60–X64, X85, and Y10–Y14.
Deaths may involve other drugs in addition to the referent drug (i.e., the one listed). Deaths involving more than one drug (e.g., a death involving both heroin and cocaine) are counted in both
totals. Caution should be used when comparing numbers across years. The reporting of at least one specific drug or drug class in the literal text, as identified using ICD–10 multiple cause-of-
death codes T36–T50.8, improved from 75% of drug overdose deaths in 2011 to 85% of drug overdose deaths in 2016.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text, 2011–2016.
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12 National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018
Technical Notes
Assessment of trends in drug-specific rates
using an adjustment factor to account for
improvements in reporting of specific drugs
The percentage of drug overdose deaths with an International
Classification of Diseases, Tenth Revision multiple cause-of-
death code T36–T50.8 indicates the reporting of specific drugs
and drug classes in mortality data. During the study period
2011–2016, the percentage of drug overdose deaths with a
multiple cause-of-death code T36–T50.8 increased from 74.9%
of deaths in 2011 to 85.4% in 2016.
The improvement in reporting of specific drugs and drug
classes during the study period could potentially influence the
observed trends in drug overdose deaths for specific drugs
(Figures 1–3). To assess the possible influence of improved
reporting, an adjustment analysis was conducted. In this
analysis, an adjustment factor was applied to each number and
age-adjusted rate for drug overdose deaths involving the top
10 drugs involved in drug overdose deaths during 2011–2016.
The adjustment factor was based on two assumptions: (1) the
percentage of deaths with one or more drugs or drug classes
specified in each year from 2011 through 2016 was the same
and equal to the percentage in 2016 (85.4%), and (2) in each
year, the distribution of deaths by specific drug was the same for
deaths that identified one or more specific drugs, as for deaths
that did not identify a specific drug. The adjustment factor was
used to estimate the rate if the percentage of deaths with one or
more drugs or drug classes specified had been uniform from
2011 through 2016.
The Technical Notes Table shows the crude rate, age-adjusted
rate, and age-adjusted rate after application of the factor to adjust
for improved reporting. The findings for the 2011–2016 trends in
rates based on observed and adjusted numbers were, in general,
the same (i.e., a statistically significant increase, decrease, or no
change in the rate) for fentanyl, oxycodone, diazepam, cocaine,
and methamphetamine. For heroin, the inflection point in 2014
was no longer found, resulting in a percent change in the rate
of about 24% per year from 2011 through 2016. For morphine,
the inflection point in 2015 was no longer found, resulting in
a percent change in the rate of about 5% per year from 2011
through 2016. For methadone, rates decreased by about 12%
per year from 2011 through 2014, and by about 3% from 2014
through 2016. For hydrocodone, there was a significant decline
in the age-adjusted rates of about 4% per year from 2011
through 2016. For alprazolam, the inflection point in 2013 was
no longer found, and as with the observed values, the increasing
trend from 2011 through 2016 was not statistically significant.
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13
Table. Crude rates, age-adjusted rates, and adjusted age-adjusted rates for drug overdose deaths involving selected drugs, 2011–2016
Drug
Crude rate Age-adjusted rate Trend 1 Trend 2 Adjusted age-adjusted rate Trend 1 Trend 2
2011 2012 2013 2014 2015 2016 2011 2012 2013 2014 2015 2016 Years
Annual
percent
change Years
Annual
percent
change 2011 2012 2013 2014 2015 2016 Years
Annual
percent
change Years
Annual
percent
change
Opioids
Fentanyl . . . . . . . . . . . 0.53 0.51 0.61 1.32 2.57 5.67 0.53 0.52 0.61 1.34 2.64 5.89 2011–2013 8.4 2013–2016 1113.3 0.60 0.59 0.67 1.42 2.71 5.89 2011–2013 6.1 2013–2016 1107.0
Heroin . . . . . . . . . . . . 1.47 1.96 2.66 3.41 4.14 4.94 1.47 1.99 2.70 3.50 4.27 5.10 2011–2014 133.7 2014–2016 120.0 1.67 2.23 2.96 3.71 4.39 5.10 2011–2016 123.7 … …
Hydrocodone . . . . . . . 1.03 0.97 0.98 1.03 0.95 0.99 1.01 0.96 0.96 1.02 0.92 0.95 2011–2016 –1.0 … … 1.15 1.08 1.06 1.08 0.94 0.95 2011–2016 1–3.7 … …
Methadone . . . . . . . . . 1.46 1.30 1.17 1.10 1.05 1.08 1.44 1.29 1.17 1.07 1.05 1.08 2011–2014 1–9.6 2014–2016 0.4 1.64 1.46 1.29 1.14 1.08 1.08 2011–2014 1–11.8 2014–2016 1–2.7
Morphine . . . . . . . . . . 1.06 1.12 1.19 1.26 1.31 1.55 1.03 1.10 1.16 1.24 1.29 1.53 2011–2015 15.7 2015–2016 17.6 1.18 1.23 1.28 1.31 1.33 1.53 2011–2016 14.6 … …
Oxycodone . . . . . . . . . 1.79 1.65 1.57 1.70 1.80 1.92 1.79 1.66 1.55 1.69 1.78 1.91 2011–2013 –6.5 2013–2016 7.0 2.04 1.87 1.70 1.79 1.83 1.91 2011–2013 –8.4 2013–2016 3.7
Benzodiazepines
Alprazolam . . . . . . . . . 1.30 1.21 1.18 1.33 1.49 1.92 1.32 1.23 1.20 1.33 1.52 1.96 2011–2013 –6.7 2013–2016 18.2 1.51 1.38 1.31 1.41 1.56 1.96 2011–2016 5.8 … …
Diazepam . . . . . . . . . . 0.54 0.50 0.51 0.55 0.56 0.63 0.54 0.49 0.50 0.55 0.55 0.63 2011–2016 3.5 … … 0.61 0.55 0.55 0.58 0.56 0.63 2011–2016 0.7 … …
Stimulants
Cocaine . . . . . . . . . . . 1.63 1.52 1.68 1.85 2.28 3.50 1.62 1.52 1.67 1.85 2.29 3.55 2011–2016 118.4 … … 1.85 1.71 1.83 1.96 2.36 3.55 2011–2016 115.2 … …
Methamphetamine . . . 0.61 0.72 1.01 1.18 1.58 2.09 0.62 0.73 1.02 1.18 1.60 2.12 2011–2016 128.6 … … 0.71 0.82 1.12 1.25 1.64 2.12 2011–2016 125.1 … …
… Category not applicable.
1Significant change in rate, p < 0.05.
NOTES: Drug overdose deaths are identified using International Classification of Diseases, Tenth Revision underlying cause-of-death codes X40–X44, X60–X64, X85, and Y10–Y14. Deaths may involve other drugs in addition to the referent drug
(i.e., the one listed). Deaths involving more than one drug (e.g., a death involving both heroin and cocaine) are counted in both rates. Trends in death rates were evaluated using the Joinpoint Regression Program set to identify a maximum of two
joinpoints.
SOURCE: NCHS, National Vital Statistics System, Mortality files linked with death certificate literal text, 2011–2016.
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National Vital Statistics Reports, Vol. 67, No. 9, December 12, 2018
Contents
Abstract.
Introduction
Methods
Data source and study popu
Identifying drug mentions and involvement of the drug in the death
Analysis
Assessing improvement in reporting on death certificates.
Results.
Most frequently mentioned drugs.
‘Age-adjusted rates for drug overdose deaths involving the most
frequently mentioned drugs, 2011-2016
Drug overdose deaths in 2016 involving multiple drugs
Most frequently mentioned drugs involved in drug overdose
deaths in 2016, by intent of death .
Discussion. . . -
Findings for specific drugs
Data considerations and study limitations
Conclusions
References.
Detailed Table.
Technical Notes .
ion
wwwennnas
Ne
Suggested citation Copyright information
Hedegaard H, Bastian BA, Trinidad JP, Spencer All material appearing in this report is in
M, Warner M. Drugs most frequently involved in the public domain and may be reproduced
drug overdose deaths: United States, or copied without permission; citation as to
2011-2016. National Vital Statistics Reports; source, however, is appreciated.
vol 67 no 9. Hyattsville, MD: National Center for
Health Statistics. 2018.
National Center for Health Statistics
Charles J. Rothwell, M.S., M.B.A., Director
Jennifer H. Madans, Ph.D., Associate Director for
Science
Office of Analysis and Epidemiology
Irma E. Arispe, Ph.D., Director
Irma E. Arispe, Ph.D., Acting Associate Director for
Science
Division of Vital Statistics
Steven Schwartz, Ph.D., Director
Hanyu Ni, Ph.D., M.PH., Associate Director for
Science
For e-mail updates on NCHS publication releases, subscribe online at: htlps:/www.cde. govinchs/govdelivery.htm.
For questions or general information about NCHS: Tel: 1-800-CDC-INFO (1-800-232-4636) « TTY: 1-888-232-6348
Internet: https:/www.cde. govinchs « Online request form: https://www.cde. gov/info
DHHS Publication No. 2019-1120 * CS298465
PSI-HHS-00000481 4213
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— Page 79 of 197 —
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
From: "Shimabukuro, Tom (CDC/DDID/NCEZID/DHQP’
To: "Sharan, Martha (CDC/DDID/NCEZID/DHQP)" =~ of John(CDC/DDID/NCEZID/DHQP)"
Ce: "Nordlund, Kristen (CDC/OD/OADC)" >, "Thompson, PerStephanie
(CDC/DDID/NCEZID/DHQP)" >, "Marquez, Paige L.
(CDC/DDID/NCEZID/DHQP)" >, "Vaccine Safety (CDC)"
a
Subject: RE: Reporter inquiry
Date: Thu, 23 Jun 2022 12:28:31 +0000
Importance: Normal
Inline-Images: image001.png
Okay, but the main reason we didn’t do PRR is b/c FDA EB data mining is the ‘gold standard’ for disproportionality analysis
so we had a better and more efficient way of doing disproportionality analysis at a time when we were occupied trying to
monitor an onslaught of reports. There really isn’t a reason for CDC to do PRR if FDA is conducting EB data mining b/c it’s
basically redundant. Now that we are further along in the pandemic and we better understand some of the limitations of
FDA’s EB data mining for COVID-19 vaccines we are doing some exploratory work with PRR, but it’s still not a major
component of our monitoring.
| find some of the statements in the response a bit problematic.
| disagree with this statement: Various technica imitations, including insufficient data precluded PRR analyses during
that time in the vaccination campaign. PRR is a simple (maybe overly simplistic) mathematical calculation. There are no
technical limitations to doing PRR, it’s easy, and there are plenty of data in VAERS to do PRR whenever we want to and on
whichever vaccines we choose. The issue is whether it’s a good idea for CDC to do PRR when FDA is doing EB data mining
(see below).
| somewhat disagree with ths statement: PRR/analyses of COVID=19 vaccines early in the vaccination campaign were
inappropriate and thus not conducted. It’s only inappropriate in the sense that EB data mining is a better test of
disproportionality b/c PRR tends to generate all kinds of spurious findings. FYSA, the Uppsala monitoring center in Europe,
which is affiliated with WHO, uses PRR and ROR as its primary disproportionality analysis. Also, the statement seems to
indirectly imply that it might be appropriate to use PRR now (vs. early), but | would questions whether PRR is appropriate
even now. The test still has all its original limitations.
| think the main message should be that FDA’s EB data mining supersedes PRR in importance and from the perspective of
generating informative data. CDC surveillance focus early on was descriptive analysis of large volumes of data and
focusing on adverse events of special interest (e.g., anaphylaxis).
From: Sharan, Martha (CDC/DDID/NCEZID/DHQP) <j>
Sent: Thursday, June 23, 2022 8:01 AM
To: Shimabukuro, Tom (CDC/DDID/NCEZID/DHQP) >; Su, John (CDC/DDID/NCEZID/DHOP)
Cc: Nordlund, Kristen (CDC/OD/OADC) >; Thompson, PerStephanie (CDC/DDID/NCEZID/DHOP)
>; Marquez, Paige L. (CDC/DDID/NCEZID/OHOP) <M>; Vaccine Safety (CDC)
>
Subject: RE: Reporter inquiry
Hi Tom and John:
| think this reporter is going to need adequate information from CDC to write her piece countering the CHD.
We can point her to ACIP presentations ands studies, but | don’t think she’s going to be able to build a piece on her own
from all that material, especially if she has not been following it.
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So, I think the information John provided will be much more helpful. We may need to edit it down just a bit, but I can
work on that. I can also reach out to the reporter to get a reading on how much detail she needs.
There have been 2 inquiries about this: AP and Washington Examiner.
Thanks,
Martha
Martha Sharan
Public Affairs
CDC/Division of Healthcare Quality Promotion
From: Shimabukuro, Tom (CDC/DDID/NCEZID/DHQP) < >
Sent: Wednesday, June 22, 2022 5:42 PM
To: Su, John (CDC/DDID/NCEZID/DHQP) < >; Sharan, Martha (CDC/DDID/NCEZID/DHQP) < >
Cc: Nordlund, Kristen (CDC/OD/OADC) < >; Thompson, PerStephanie (CDC/DDID/NCEZID/DHQP)
< >; Marquez, Paige L. (CDC/DDID/NCEZID/DHQP) < >; Vaccine Safety (CDC)
< >
Subject: RE: Reporter inquiry
Can we just simply point the reporter to the publications website and the ACIP presentations website to demonstrate the
monitoring and signal detection/signal assessment activities that have been happening since December 2020. We could
also say that PRR is a form of disproportionality analysis and FDA empirical Bayesian data mining is the primary
disproportionality analysis used in VAERS. CDC selectively uses PRR as a supplement or complement to FDA’s EB data
mining.
From: Su, John (CDC/DDID/NCEZID/DHQP) < >
Sent: Wednesday, June 22, 2022 5:20 PM
To: Sharan, Martha (CDC/DDID/NCEZID/DHQP) < >
Cc: Nordlund, Kristen (CDC/OD/OADC) < >; Thompson, PerStephanie (CDC/DDID/NCEZID/DHQP)
< >; Marquez, Paige L. (CDC/DDID/NCEZID/DHQP) < >; Vaccine Safety (CDC)
< >; Shimabukuro, Tom (CDC/DDID/NCEZID/DHQP) < >
Subject: RE: Reporter inquiry
Hi folks,
Adding PerStephanie to this email, as she’s more versed in FOIA matters, and can advise if any details I provide
are privileged (ie, shouldn’t be released in response to this inquiry). Also adding Paige, who can provide more technical
details if I get my facts crossed, and the Vaccine Safety mailbox for tracking purposes. And Tom, for his awareness (it’s AP,
after all).
The FOIA below mentioned specified analyses of proportionality reporting ratios (PRRs) during February 1, 2021,
through Sept. 30, 2021. You might recall that emergency use authorization (EUA) for the mRNA vaccines was granted in
December 2020, and EUA for Janssen’s vaccine was in March 2021. While there was a considerable reporting volume to
VAERS during this time period, preliminary reports of adverse events of special interest (AESIs) were more limited. Thus,
during the time period specified, we were early in the vaccination campaign, and insufficient data had accrued during that
time for PRR analysis.
Also, selection of appropriate comparator vaccines was a challenge: ideally, PRRs are conducted between
vaccines of similar type or technology (e.g., comparing live virus vaccines like MMR and varicella (Varivax), or conjugated
vaccines like Prevnar (pneumococcal conjugate vaccine) and the meningococcal conjugate vaccines). No such comparator
existed for the mRNA vaccines. We’ve performed some draft analyses against the influenza vaccines (with no surprising
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results – a lot of the tagged adverse events (AEs) were typical of the mRNA vaccines); these draft analyses were
performed after the period specified in the FOIA – and again, they were draft, so we wouldn’t want to consider them
formal analyses.
Lastly, interpretation of PRRs is tricky – the usual threshold we use is 2.0, indicating that a given AE was reported
after one vaccine twice as often as after the comparator vaccine(s). As you can imagine, quite a few AEs yield a PRR of 2.0
or greater. This threshold indicates no statistical significance; it’s an arbitrary cut point, like selecting a p value of 0.05
(which corresponds to a given outcome in 5 of 100 occurrences, such as 5 heads out of 100 coin flips). In sum, PRRs are
noisy and challenging to interpret. To call a PRR of 2 or greater a “safety signal” (as the author of the CHD article does) is a
gross overstatement.
CDC (and VAERS specifically) was engaged in safety signal analysis during the period specified in the FOIA – but
what the CHD author fails to grasp is that “signal detection” is a sum of both quantitative and qualitative analysis. Case in
point: thrombosis with thrombocytopenia syndrome (TTS) after Janssen’s vaccine was identified during the FOIA period.
VAERS contacted the Advisory Committee on Immunization Practices (ACIP) within 3 weeks of initiating use of the vaccine
when 6 cases of cerebral venous sinus thrombosis (CVST) with low platelets had been identified. With only 6 cases of
CVST, no thromboembolic symptom would flag via PRR, or even Empirical Bayesian data mining, analyses. However, a
similar syndrome had been observed after AstraZeneca’s vaccine in Europe – and, like Janssen’s vaccine, AstraZeneca’s
vaccine was based on an adenoviral vector. In this case, VAERS identified this safety signal not through quantitative
techniques per se, but via pattern recognition.
With the above background, I might suggest the following response:
“The author of the Children’s Health Defense article mischaracterized safety signal analysis. In brief,
Proportionality Reporting Ratios (PRRs) can be helpful in identifying potential vaccine safety concerns, or “safety signals”,
but PRRs are a single tool and do not by themselves indicate such safety signals.
PRRs compare the counts of reports of a given adverse event (AE) after one vaccine to after another vaccine (or
vaccines). For example, a PRR of 2.0 indicates that a given AE was reported twice as often after one vaccine as after
another vaccine(s). A known limitation of the Vaccine Adverse Event Reporting System (VAERS) is that reporting to VAERS
can be influenced by numerous factors, including increased public attention or awareness of a given AE. Thus, a PRR by
itself does not constitute a safety signal: there can be numerous explanations for why a PRR might be elevated for a given
vaccine. PRRs can be helpful tools, but they do not indicate potential safety concerns with a vaccine on their own.
Further, the FOIA requested PRR analyses from early in the COVID-19 vaccination campaign. Various technical
limitations, including insufficient data, precluded PRR analyses during that time in the vaccination campaign.
More importantly, CDC has been engaged in safety signal surveillance since COVID-19 vaccines have been in use.
During the first month of their availability, data on anaphylaxis after mRNA COVID-19 vaccines were published (including
in highly visible journals, like the Journal of the American Medical Association (JAMA)), indicating an observed incidence
comparable to after other vaccines. VAERS detected what would become known as thrombosis with thrombocytopenia
syndrome (TTS) after Janssen’s vaccine, leading to a pause in the use of the vaccine mere weeks after its use was initiated.
VAERS reviewed reports of myocarditis after mRNA COVID-19 vaccines during Summer 2021, providing a highly thorough
characterization of such reports. These examples indicate that the vaccine safety surveillance systems in use by CDC and
FDA identify potential vaccine safety concerns in a timely and effective manner.
In sum, PRR analyses of COVID-19 vaccines early in the vaccination campaign were inappropriate and thus not
conducted. However, CDC and FDA have been actively engaged in vaccine safety surveillance ever since COVID-19 vaccines
have been in use.”
Please let me know what you think, and if you have any comments, feedback, or any questions. Thanks!
John
From: Sharan, Martha (CDC/DDID/NCEZID/DHQP) < >
Sent: Wednesday, June 22, 2022 12:51 PM
To: Su, John (CDC/DDID/NCEZID/DHQP) < >
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Ce: Nordlund, Kristen (CDC/OD/OADC) ; ti‘
Subject: FW: Reporter inquiry
Hi John... wanted to check with you on this request from Associated Press. Can you offer a response to this one?
Vm cc’ing Kristen, since the request came through her and we don’t have a standard response to what the reporter is
asking.
Thanks,
Martha
Martha Sharan
Public Affairs
CDC/Division of Healthcare Quality Promotion
Hi,
I'm a fact-checking reporter at The Associated Press. I’m looking into a new post by Children’s Health Defense that is being
shared on social media, alleging that a FOIA response from CDC shows the agency “admitted it never analyzed the Vaccine
Adverse Event Reporting System for safety signals for COVID-19 vaccines”:
https://childrenshealthdefense.org/defender/cdc-vaers-covid-vaccine-safet
Angelo Fichera
Reporter, News Verification
The Associated Press
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From: "Menschik, David" < >
To: "Su, John (CDC)" < >
Subject: data mining limitations
Date: Wed, 22 Sep 2021 16:33:23 +0000
Importance: Normal
Attachments: mRNA_6mo_safety_review-update98forOS_091521.docx
Hi John,
In the mRNA vaccine review article that we’re co-authors on, we recently expanded data mining limitations section as per
attached work-in-progress draft (Hannah indicated acceptance of the language) and excerpt below for convenience:
EB data mining has multiple limitations22 including that an absence of a disproportionality alert does not rule out
presence of a safety problem. Additionally, since most reports received during this surveillance period involved
COVID-19 vaccines, disproportionately scores (which are adjusted by year to control for time-dependent,
potentially confounding, exposure and outcome variables) can be muted by COVID-19 vaccine reports
contributing substantially to the comparator group, particularly if both mRNA COVID-19 vaccines are associated
with the same adverse event.
Thought it might be helpful to share this manuscript update with you, especially if folks on your end may be placing excess
value on data mining alerts (EB05>2) or the absence of specific data mining alerts.
Best,
David
PS: If you’d like to discuss more, happy to do so by phone (better suited than email…)
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1
Reactogenicity and Adverse Events during the First Six Months of mRNA COVID-19 Vaccination in the
United States: A Prospective Observational Study of Reports to Vaccine Adverse Events Reporting
System (VAERS) and v-safe
Hannah G. Rosenblum, MD1,2; Julianne M. Gee, MPH1; Ruiling Liu, PhD1; Paige L. Marquez, MSPH1;
Bicheng Zhang, MS1; Penelope Strid, MPH1, Winston E. Abara, MD1; Michael M. McNeil, MD, MPH1;
Lauri E. Markowitz, MD1; Tanya R. Myers, PhD1; Anne M. Hause, PhD, MSPH1; John R. Su, MD, PhD1;
Bethany Baer, MD3; David Menschik, MD, MPH3; Tom T. Shimabukuro, MD, MPH, MBA1, David K.
Shay, MD, MPH1
1CDC COVID-19 Response Team, Centers for Disease Control and Prevention, Atlanta, Georgia
2Epidemic Intelligence Service, Centers for Disease Control and Prevention, Atlanta, Georgia
3Food and Drug Administration, Silver Spring, Maryland
Corresponding author: Julianne Gee,
The findings and conclusions in this report are those of the authors and do not necessarily represent the
official position of the Centers for Disease Control and Prevention (CDC) or the Food and Drug
Administration (FDA)
Acknowledgements
We wish to acknowledge the following contributors: CDC: Amelia Jazwa, Tara Johnson, Charles Licata,
Stacey Martin; FDA: Jane Baumblatt, Deborah Thompson, Kerry Welsh, Narayan Nair, Kosal Nguon
(Commonwealth Informatics); v-safe participants; Oracle v-safe development team. Mention of a product
or company name is for identification purposes only and does not constitute endorsement by the CDC or
the FDA.
Target journal: Lancet ID
Manuscript word count: ***/3500
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Abstract (word count: 233/250)
Background: In December 2020, two mRNA-based COVID-19 vaccines were authorized for use in the
‘United States. Vaccine safety was monitored using Vaccine Adverse Event Reporting System (VAERS),
a national passive surveillance system, and v-safe, an active surveillance system.
Methods: VAERSand v-safe data from December 14, 2020—June 14, 2021 were analyzed. Empirical
Bayesian data mining was used to identify disproportional reporting of events by vaccine in VAERS.
Proportions of v-safe participants reporting local and systemic reactions or health impacts the week
following first and second vaccine doses were determined.
Findings: During the analytic period, 298,792,852 total doses of mRNA vaccines were administered in
the United States. VAERS received and processed 340,522 reports; 92-1% were classifiedas non-serious;
6-6%: serious, non-death; and 1-3% as death. Over half of 7,914,583 v-safe participants self-reported
local and systemic reactogenicity, more frequently after dose 2. Injection-site pain, fatigue, and headache
‘were most commonly reported during days 0~7 following vaccination. Reactogenicity was reported most
frequently one day after vaccination and rapidly declined; most reported reactions were mild. More
reports of being unable to work or do normal activities occurred after dose 2 (32-1%) than dose 1
(11-9%); <1% of participants reported seeking medical care after |vaccinati Commented [RH(Z]: Note all death
results/interpretation has been removed from abstract
Rosenblum, Hannah (CDC)
2021-09-08 10:30:00
Interpretation: Safety data from >298 million doses of MRNA COVID-19 vaccine administered in the
first 6 months of the U.S. vaccination program show the majority of reported adverse events were mild
and short in duration.
Funding: No extemal sources of funding were used. CDC received nonfinancial technical support to
develop and maintain the v-safe infrastructure from Oracle.
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Introduction
In December 2020, two messenger RNA (mRNA)coronavirus disease 2019 (COVID-19) vaccines
(BNT162b2 developed by Pfizer-BioNTech and mRNA-1273 developed by Moderna) were granted
Emergency Use Authorization (EUA) by the U.S. Food and Drug Administration (FDA) as 2-dose series
and recommended for use by the Advisory Committee on Immunization Practices (ACIP).!2 The mRNA.
vaccine platform uses lipid nanoparticles as a carrier system for the mRNA which encodes the SARS-
COV-2-spike protein], In clinical trials, both mRNA COVID-19 vaccines had acceptable safety profiles+
Reactogenicity (e., local and systemic reactions) was observed afer receipt of vaccine in clinical trials of
both vaccines; the most frequently reported symptoms included injection site pain, fatigue, and headache.
Reactogenicity was more frequently reported following dose 2, and more common among participants
aged <65 years5
Post-authorization safety monitoring is necessary to better understand the safety profiles of mRNA-based
COVID-19 vaccines in larger and more heterogeneous populations 6 Phased administration ofCOVID-19
vaccines in the United States began with healthcare workers and residents of long-term care facilities and
expanded to the general population by spring 2021; however, implementation plans varied by state.” The
Vaccine Adverse Event Reporting System (VAERS), a spontaneous reporting (i.e., passive surveillance)
system, and v-safe,? a new active monitoring system, were the primary safety data sources used in initial
reports of adverse events following administration of COVID-19 vaccines in the United States
vaccination program. Since the inception of the program, regular vaccine safety updates from these
systems have been provided through websites, publications, and presentations to advisory committees.!°14
Here, we review VAERS and v-safe safety data during the first six months of the U.S. vaccination
program, when over 298 million doses of mRNA COVID-19 vaccines were administered.
‘Commented [BR(2]: Sounds awkward as written.
‘Actually, the lipid nanoparticles envelop the mRNA, which
encodes the genetic sequence information for the viral
'SARS-CoV-2 spike protein, Another way to putt “The
‘messenger RNA vaccine platform uses lipid nanoparticles as
a carrier system for the mRNA which encodes the SARS-CoV-
2 spike protein”.
Office of Science
2021-08-11 07:50:00
‘Commented [RH(3R2]: thanks- has been edited
Rosenblum, Hannah (CDC)
2021-08-17 14:32:00
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4
Methods
VAERS
VAERS is an established, national spontaneous reporting system that serves as an early warning system
for detecting potential safety problems for vaccines authorized or licensed in the United States.8 Co-
administered by Centers for Disease Control and Prevention (CDC) and FDA, VAERS accepts reports
from health care providers, manufacturers, and the public. VAERS reports include information about the
vaccinated person, type of vaccine administered, and the adverse event (AE) experienced. For this
analysis, VAERS reports submitted and processed by June 14, 2021 were included.15 Processed reports
were those checked for data quality, de-duplicated, and coded using the Medical Dictionary for
Regulatory Activities (MedDRA) terminology.8 Each VAERS report may be assigned more than one
MedDRA Preferred Term (PT); PTs do not necessarily indicate a medically confirmed diagnosis, and
include signs and symptoms of illness and results of diagnostic tests.
Based on the Code of Federal Regulations,16 VAERS reports were classified as serious if any of the
following were documented: hospitalization, prolongation of existing hospitalization, permanent
disability, life-threatening illness, congenital anomaly or birth defect, or death. Adverse events of special
interest (AESI)17 were selected for enhanced COVID-19 vaccine safety monitoring based on biologic
plausibility, previous vaccine safety experience, and theoretical concerns related to COVID-19.17 Death
certificates and autopsy reports were requested for death reports. CDC physicians reviewed VAERS
reports and available death certificates for each decedent to form an impression about cause of death.
Causes of death were further categorized into the following groups, using the National Center for Health
Statistics the 15 most common major International Classification of Disease, Tenth Revision (ICD-10)
diagnostic categories reported on U.S. death certificates18: COVID-19 disease; other (i.e., diagnosis did
not belong in one of the other pre-specified categories); or unknown/unclear if a likely cause could not be
determined.
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V-safe
‘V-safe is a voluntary smartphone-based system that uses text messaging and secure web-based surveys to
actively monitor vaccine safety, and has been specifically designed to gather information about COVID-
19 vaccine AEs, particularly for common local injection site and systemic reactions.!9 V-safe participants
receive text messages that link to web-based health check-ins and respond to questions in surveys
following vaccination, initially daily (days 0~7), then weekly (days 14~42) and lastly at 3, 6 and 12
months post vaccination. The system resets to the initial survey frequency after receipt of dose 2. We
analyzed survey reports from days 0~7 for reactogenicity, severity® (mild, moderate, severe), and health
impact (i., unable to perform normal daily activities, unable to work, and/or received care froma
medical professional). Participants who reported receiving medical care were contacted by v-safe staff
and VAERS reports were completed if clinically indicated.
Data analyses
‘We conducted descriptive analyses ofavailable VAERS and v-safe data from December 14, 2020-June
14, 2021 following first and second doses of BNT162b2 andmRNA-1273 vaccines. For VAERS,
bivariate analyses included sex, age groups, race/ethnicity, serious AEs, time from vaccination to reported
death (e., onset interval) for death reports, cause of death for death reports, and vaccine
type/manufacturer administered. Unadjusted, rude reporting rates to VAERS were calculated for AEs
using the total number of doses of mRNA vaccine administered during the six-month period.COVID-19
vaccine administration data were provided through CDC’s COVID-19 Data Tracker.” }
Empirical Bayesian (EB) data mining was used to detect disproportional |eporting ofpost-vaccine
outcomes by vaccine received among all VAERS serious and non-serious reports received by June 14,
20212! This statistical method calculates observed to expected PT pairing by comparing a specific _/
vaccine-PT pair to all vaccine-PT pairs in VAERS, adjusting for age, sex, and year of vaccination”
‘Commented [RH(4]: | removed crude everywhere else,
but I think good to leave here- what do others think?
Rosenblum, Hannah (CDC)
2021-09-08 11:49:00
Commented
[BR(5]:
Required:
This is unclearto the general reader. Please clarify
“disproportionately” to what.
Office of Science
2021-08-11 12:05:00
‘Commented [RH(6R5]: Thank you- this is a typo! It
should have read “disproportionately” but rather
“disproportionality” or as | have modified it to
“disproportional reporting”. Thank you!
Rosenblum, Hannah (CDC)
2021-08-11 17:03:00
‘Commented [BR(7]: Required: tis unclear how the rate
of expected PT pairings were determined. Please explain.
Office of Science
2021-08-11 09:45:00
‘Commented [RH(8R7]: Have expanded the phrase and
re-checked the references as well as added another
reference suggested by FDA. Thank you!
Rosenblum, Hannah (CDC)
2021-08-11 17:04:00
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6
These ratios are ranked by the lower 5% bound of the EB geometric mean confidence interval (EB05) and
a standard alert threshold of EB05 >2 was used. An EB05 >2 represents a high degree of confidence that
a vaccine-PT pair was reported at least twice as frequently as expected. In addition to overall ratios, ratios
were calculated for age group, sex, serious reports, and death reports.
V-safe participants who responded to at least one health check-in survey during day 0–7 after vaccination
were included in analyses. Descriptive statistics were calculated for participants characteristics (sex, age,
race/ethnicity), reaction (type and severity) and health impact by manufacturer, dose number, and number
of days following vaccination.
SAS software, version 9.4 (SAS Institute; Cary, NC, USA) was used for analyses. Both VAERS and v-
safe conduct surveillance as a public health function and are exempt from institutional review board
review. Activities were reviewed by the CDC and were conducted in accordance with applicable federal
law and CDC policy (See: 45 C.F.R. part 46.102(l)(2), 21 C.F.R. part 56; 42 U.S.C. §241(d); 5 U.S.C.
§552a; 44 U.S.C. §3501 et seq.).
Results
During December 14, 2020–June 14, 2021, a total of 298,792,852 doses of mRNA COVID-19 vaccines
were administered in the United States: 167,177,332 were BNT162b2 and 131,639,515 were mRNA-
1273 (Supplemental Table 1). A greater proportion of vaccines were administered to females (53·2%)
compared with males (45·8%). The median age at vaccination was 50 years (inter-quartile range [IQR]:
33–65) for BNT162b2 and 56 years (IQR: 39–68) for mRNA-1273, respectively. Non-Hispanic White
persons accounted for 38·4% of vaccine recipients; however, race/ethnicity was unknown for 34·9% of
all vaccine recipients.
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VAERS
‘During the analytic period, VAERS received and processed a total of 340,522 reports: 164,669 were
following BNT162b2 and 175,816 were following mRNA-1273 vaccine administration (Table 1). Of
these reports, 92:1% were classified as non-serious, 6-6% were serious, not resulting in a death (non-
death), and 1-3% were deaths. Seventy-two percent of reports were among females, and 45-3% of reports
‘were among vaccine recipients aged 18-49 years; median age was 50 years (IQR: 36-64). Fifty percent of
those reporting race/ethnicity identified as non-Hispanic White; for 22-1%, race/ethnicity was unknown.
The most common MedDRA PTs among non-serious reports were headache (20-4%), fatigue (16-6%),
pyrexia (16-3%), chills (15-79), and pain (15-2%). The most common MedDRA PTs among serious
reports were dyspnea (15-4%), death (14-1%), pyrexia (11-0%), fatigue (9-7%), and headache (9-5%)..
The reporting rate to VAERS was 1,049 non-serious reports per million doses, and 90 serious reports per
million doses (Table 2). Among the pre-specified AESIs, reporting rates ranged from 0-1 narcolepsy
reports per million doses administered to 32 COVID-19 disease reports per million doses administered.
There were 4,496 reports of death in VAERS (Table 3). After review, 24 reports were excluded because
ofmiscoding of death or duplicate reporting. Of the 4,472 reports of deaths analyzed, 2,087 (46-7%) were
reported following BNT162b2 and 2,385 (53-3%) following mRNA-1273. Females accounted for 42-6%
ofreported deaths; the median age of decedents was 76 years (IQR: 66-86). More than 80% of deaths
‘were reported among individuals aged 60 years or older (reporting rate of death per million doses
administered by age group: 60-69 years, 2-6; 70-79 years, 3-7; 80-89 years, 3-8; >90 years, 2-1).18-3%
of decedents were identified as long-term care facility residents. Death certificates or autopsy reports
were available for clinical review for 808 (18-1%) reports of deaths analyzed (Table 4). Among these 808
reports, causes of death were most commonly diseases of the heart (46-5%) and COVID-19 disease
(12-6%). (Causes of death among reports with death certificate or autopsy available are shown by age in Commented [RH(9]: These figures/tables are new
Rosenblum, Hannah (CDC)
Figure 1 and Supplemental Table 2. Among the 3,664 reports of death without a death certificate or 2021-09-08 11:54:00
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autopsy, causes of death were most commonly unknown/unclear (54-1%), diseases of the heart (17-0%),
and COVID-19 disease (8-7%). Supplemental Table 3 displays specific impressions within each category
of cause of death, for all deaths, and for those with death certificate or autopsy. Time interval to death
following vaccination was available for 4,119 reports (92-1%) and the median time interval was 10-0
days (range: 0—161 days) after vaccination. The greatest number of reports of deaths occurred on day 1
(10-5%) and day 2 (7-0%) following vaccination (Supplemental Figure 1).
EB Data Mining
No adverse health outcome alerts were identified in EB data mining.However, five mRNA COVID-19
alerts with disproportionality (EB0S>2) were identified during the surveillance period. For BNT162b2
‘vaccine, ‘product preparation issue’ alerted among all reports (EBOS: 2-09; N=757), and among adults
265 years (EBOS: 2:10; N=205), females (EBOS: 2-03; N=394), and males (EBOS: 2-01; N=350). Two
terms forBNT162b2 vaccine alerted in adults >65 years: ‘investigation’ (EBOS: 2.06, N=163) and
“weight” (EBOS: 2-01; N=139). For mRNA-1273 vaccine, two terms alerted among all reports: ‘poor
quality product administered’ (EBO5: 2-43; N=1,506), and ‘product temperature excursion issue’ (EBOS:
2-17; N=720).
vsafe
‘During the analytic period, 7,914,583 mRNA COVID-19 vaccine recipients enrolled in v-safe and
completed at least one post-vaccination health survey during days 0-7 after vaccination (Table 5). The
median age of v-safe participants was 50 years (IQR: 36-63), 62-9% were female, and 59-4% identified
as non-Hispanic White. A total of 6,775,515 participants completed at least one survey during day 0-7
after dose 1 (3,455,778 following BNT162b2 and 3,319,737 following mRNA-1273). Of these
participants, 68-6% reported a local injection site reaction and 52-7% reported a systemic reaction. Of the
5,674,420 participants who completed a survey after dose 2, a greater percentage reported an injection site
Commented [RH(10]: Not sure if sentence needed
Rosenblum, Hannah (CDC)
2021-09-08 11:56:00
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9
reaction (71·7%) and/or a systemic reaction (70·8%) (Table 6). Local injection site reactions were
reported more frequently after mRNA-1273 (dose 1: 73·3%; dose 2: 78·4%) than after BNT162b2 (dose
1: 64·0%; dose 2: 65·3%). A similar pattern was found for systemic reactions after mRNA-1273 (dose 1:
54·3%; dose 2: 75·8%) versus BNT162b2 (dose 1: 51·3%; dose 2: 66·1%). The most frequently reported
events after dose 1 of either mRNA vaccine included injection site pain (66·2%), fatigue (33·9%), and
headache (27·0%); these reactions were also more frequent after dose 2: injection site pain (68·6%),
fatigue (55·7%), headache (46·2%). Differences in proportions of reactogenicity by dose number were
similar after stratifying by age group (<65 vs. ≥65 years) and sex. More reactogenicity was reported
among younger participants aged <65 years and by females. (Supplemental Table 4).
Proportions of reported severity of reactions by manufacturer, dose number, and day since vaccination are
shown in Figure 2. The majority of reported symptoms were mild. Participants reported moderate and
severe reactogenicity most commonly on day 1 after dose 2 of either vaccine. The proportion of
participants who reported symptoms was greatest on day 1 and then decreased on subsequent days. The
highest proportion of participants reported severe symptoms on day 1 following dose 2 of mRNA-1273
(Supplemental Table 6). On all other days, proportions of participants reporting severe symptoms did not
exceed 3.0% for any individual symptom (Supplemental Tables 5 and 6).
Reported health impact was greater following dose 2 of either mRNA vaccine (32·1%) compared with
dose 1 (11·9%) and after mRNA-1273 of either dose compared with BNT162b2 (Table 6). After dose 1 of
either mRNA vaccine, 9·7% of participants were unable to do normal activities and 4·5% were unable to
work. After dose 2 of BNT162b2, 20·5% were unable to do normal activities, and 12·3% were unable to
work. After dose 2 of mRNA-1273, 32·8% were unable to do normal activities, and 20·0% were unable to
work. Less than 1·0% reported receiving medical care after receiving either dose from either
manufacturer. Fewer participants reported an emergency room visit (dose 1: 0·1%; dose 2: 0·2%) or
hospitalization (dose 1: 0·03%; dose 2: 0·04%).
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When stratified by sex, females reported a health impact more frequently than males, peaking on day 1
after vaccination (Supplemental Figure 2). Following dose 2 of mRNA-1273 vaccine, 41·4% of females
reported in the day 1 survey an inability to perform normal activities, and 23·5% an inability to work.
Among males receiving dose 2 of mRNA-1273 on the day 1 survey, 25·6% were unable to perform
normal activity and 16·9% were unable to work (Supplemental Table 7).
Discussion
During the first six months of the U.S. COVID-19 vaccination program, over 298 million doses of mRNA
vaccines were administered. COVID-19 vaccine safety in the United States has been monitored with well-
established systems, including the Vaccine Safety Datalink23 and VAERS, and a system developed
specifically for COVID-19 vaccine safety monitoring, known as v-safe. The post-authorization safety
profile for mRNA COVID-19 vaccines after six months of use in the United States is largely consistent
with data presented in the pre-authorization clinical trials.3,4 Data from U.S. safety monitoring systems
have been presented regularly to ACIP’s COVID-19 Vaccine Safety Technical Subgroup (VaST) work
group24 and at public ACIP meetings.25 Data have been presented concerning cases of clinically serious
AEs, including anaphylaxis,13 thrombosis with thrombocytopenia syndrome (TTS),26 myocarditis,27 and
Guillain-Barré Syndrome (GBS)28 reported following receipt of COVID-19 vaccines. ACIP has assessed
the benefit-risk balance of each of the currently authorized U.S. COVID-19 vaccines; these evaluations
have not prompted any changes in U.S. COVID-19 immunization recommendations.13,27,28
Our main findings are similar to those obtained from diary-based reporting in pre-authorization clinical
trials and early post-authorization reports – data from all reports demonstrate substantial local and
systemic reactogenicity.3-5,10,11 In both VAERS and v-safe, local injection site and systemic reactions were
commonly reported, and in v-safe, transient reactions were reported more frequently following mRNA-
1273 compared with BNT162b2, and more frequently following dose 2. Overall, females and individuals
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aged <65 years reported AEs and reactions more frequently. These findings are similar to those from a
large-scale study about reactogenicity conducted in the United Kingdom.29 Host characteristics known to
influence reactogenicity, including age, sex, and the presence of underlying medical conditions, might be
associated with this pattern of findings.30 Females have more vigorous antibody responses31 to certain
vaccines and also tend to report more severe local and systemic reactions to influenza vaccine.32 Females
may also be more likely than males to respond to surveys33,34 and we hypothesize that younger individuals
may be more comfortable with smartphone-based surveys and more likely to respond to survey
questions.35,36
The impact of vaccination on daily life activities was most frequently reported on the first day after
vaccination. Reports about the health impact measures used in v-safe, while self-assessed and subjective,
correlate with reports about reactogenicity patterns: more health impact was reported by females than
males, by participants aged <65 years compared with older participants, by persons receiving dose 2
compared with dose 1, and by those who received mRNA-1273 versus BNT162b2. Reports of seeking
medical care (including telehealth and urgent care) after receipt of either dose of mRNA vaccine were
rare, suggesting that reactogenicity was transient and manageable at home. Among those who did report
seeking medical care, only a small proportion visited an emergency department or were hospitalized.
Reactogenicity and its associated health effects, even if transient, may deter some persons from seeking
vaccination. An April 2021 survey conducted by the Kaiser Family Foundation found that nearly half
(48%) of unvaccinated adults aged <50 years expressed concern about missing work due to vaccine side
effects; this concern was reported by 55% of unvaccinated Black adults and 64% of unvaccinated
Hispanic adults.37 Employees who are provided time off may be more likely to get vaccinated, even after
controlling for other demographic factors that might influence vaccine uptake.38 These data suggest that
employee work policies that accommodate days off for vaccination and recovery from side effects may
increase vaccination coverage.39
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Increased public awareness, widespread promotion of VAERS, and outreach and education to healthcare
providers about COVID-19 EUA AE reporting requirements are likely all contributing factors to the high
volume of VAERS reports following mRNA COVID-19 vaccines as compared to established adult
‘vaccinations *|FormRNA COVID-19 vaccines in this six-month period, VAERS has processed and
received more than six times the number of average reports per year (typically 50,000 reports are received
per year for all vaccines in all age groups) For example, the number of reports of death in VAERS
following mRNA vaccine in this period exceeds the number of deaths reported to VAERS for all other
‘vaccines in a summary report from 1997-2013 by eight times.‘ |[Phe concentrated reporting of deaths on
‘Commented [RH(11]: include total number of vaers
reports yearly to highlight overall magnitude through 6
months?
Rosenblum, Hannah (CDC)
2021-09-07 14:51:00
‘Commented [S(12R11]: Yes, i think that’s a good idea
‘Shay,
David
(CDC/DDID/NCIRD/ID)
2021-09-08 08:02:00
‘Commented [RH(13R11]: Tried to use CDC wonder for
this and did some literature search, but unable to find a
readily available resource to cite- wondering if comparing to
‘the # of deaths is enough to make this point
Rosenblum, Hannah (CDC)
2021-09-08 10:37:00
days 1 and 2 following vaccination may represent reporting bias, as the likelihood to report a serious AE
may increase when it occurs in close temporal proximity to |vaccination|
Comparing deaths reported to VAERS following mRNA vaccination by cause to national mortality data*!
is challenging, as more common causes of deaths in younger individuals (for example, accidents or \
suicide) may be less likely to be reportedto VAERS. The overrepresentation of diseases of the heartas \
cause of death in general may be driven by non-specific causes of death on death certificates such as \
cardiac arrest or cardiopulmonary arrest, which are terminal events, but might be chosen if no immediate \
explanation is available. Additional studies are neededtd characterize deaths in VAERS ...???
‘Commented [RH(14R11]: Received this data from Paige-
not sure If can cite Wonder- asking her...
Rosenblum, Hannah (CDC)
‘Commented [BR(15]: Required:
Rates per million doses administered is not the same as
rates per million persons vaccinated. Rates per doses can
‘Commented [RH(16R15]: Thanksso much —we've
removed the text about rate comparisons for the reasons
you outlined
‘Commented [RH(17]: Framing around deaths evaluated
\Vaers hasn't been used to evaluate deaths following
‘Commented [BR(18]: Required:
This reporting may also reflect a true event. This hypothesis
can easily be tested in VAERS. Please discuss whethera
‘Commented [RH(L9R18]: | don't think the other VAERS
published data I've seen focuses on the timing of reported
deathsso I'm not sure how easily tested this is—any [During the 6-month period we analyzed, patterns of reports to VAERS are similar to other vaccines that \
are routinely administered to adults and the majority of reported events were non-serious “2445 None of \ |
the EB data mining alerts suggested an unexpected vaccine safety problem. Serious AEs have been
detected following receipt of COVID-19 vaccines during U.S. safety monitoring and reviewed in detail.
28 Early reports of anaphylaxis prompted recommendations about specific clinical management including
screening and kecommendation of a post-observation period following vaccination. A fier myocarditis
was observed following mRNA vaccination,‘”“* particularly in males aged <30 years, CDC issued clinical
guidance and management recommendations,” and presented a benefit-risk assessment to ACIP” The
tisk of TTS and GBS’Sis elevated following receipt of Janssen COVID-19 vaccine (Ad26.COV2.S) and
‘Commented [S(20R18]: the temp scan results may help
here. also, please note that the total number of deaths
reported to VAERS following Covid vaccination is far larger
‘Commented [RH(21R18]: Have the # of deaths
exceeded by 8 times in this period—but still not sure how to
address OS here- could use help here
‘Commented [RH(22]: This paragraph is really where |
could use some help — tried to sum some of what we've
discussed, and Tom pointed out in his last email-but | fee!
‘Commented [RH(23]: | think this paragraph should come
before the deaths paragraph now.
Rosenblum, Hannah (CDC)
‘Commented [BR(24]: Editorial:
Redundant to say “observation of a post-observation”.
Please revise.
have not been associated with mRNA COVID-19 vaccines to date.
12
‘Commented [RH(25R24]: Thank you - edited
Rosenblum, Hannah (CDC)
2021-08-11 17:07:00
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This study has several strengths and several limitations. Strengths include a large sample size and
comprehensive capture of national data from two complementary surveillance systems. Data on doses
administered are available for estimating reporting rates for VAERS, as the U.S. government provides all
COVID-19 and collects administration data from jurisdictions. Therefore, the reporting rates calculated
here use the number of mRNA vaccine doses administered as a denominator.2° while for other vaccines
the only denominators available are doses distributed, which is variably larger than dose administered. V-
safe data illustrating the effects of mRNA vaccination on daily activities and work during the week
following vaccination provide new information has not previously available. Limitations include that
‘VAERS data are based on passive surveillance, and may therefore be subject to underreporting, and
variable or incomplete reporting § For this analysis, reports of death in VAERS were individually
reviewed by physicians and follow-up is ongoing to obtain additional records for reports of death missing
death certificates, autopsy reports, or other medical records; however, not all other serious AE reports
were individually reviewed. VAERS reports require interpretation to determine if AE reports meet
clinical case definitions.*! Though EB data mining has multiple limitations” including that is used-to
screen for-safety-alerts-an absence of an disproportionality alert does not rule out presence of a safety
problem. Additionally. since most ré received. this surveillance period involved COVID-19
vaccines, disproportionately scores (which are adjusted by year to control for time-dependent, potentially
confoundin sure and outcome variables) can be muted byCOVID-19 vaccine reports contribut ‘Commented [BR(26]: Please explain ifthe v-safe systemallows for free text reporting in addition to a list of
substantially to the comparator group, particularly if both mRNA COVID-19 vaccines are associated with pee eeaas
2021-08-11 10:53:00
the same adverse event, Routine screening of VAERS reports may also not be sensitive enough to pick up ‘Commented [RH(27R26]: Thanks added
true associations, particularly if they occur in specific age groups. {V-safé is voluntary and requires ee)
smartphone accesd_ Participants are asked about pre-specified reactions; this report focused on the first 7 Seri rit fowused only on AE inv
safe for the first tion.
days post-vaccination. Because a subset of all vaccine recipients chose to participate in v-safe, the results tS ae
; ; 2021-08-11 10:55:00
likely are not generalizable to the entire vaccinated population in the United States. Participants in v-safe e 4[RH(2OR28}. Added to imtatons
Rosenblum, Hannah
may also be lost to follow up as there is not a requirement for continuous enrollment. ee a
13
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During the first six months of the U.S. COVID-19 vaccination program, more than 50% of the eligible
population received at least one dose of COVID-19 vaccine.20 VAERS and v-safe data from this period
demonstrate a post-authorization safety profile for mRNA COVID-19 vaccines that is consistent with pre-
authorization trials3,4 and early post-authorization surveillance reports.10,11 Serious AEs have been
identified following mRNA vaccinations; however, based on the most current information, these events
are rare. Vaccines are the most effective tool to preventing serious COVID-19 disease outcomes and the
benefits of immunization in preventing serious morbidity and mortality clearly favor vaccination.26-28
VAERS and v-safe, two complementary surveillance systems, will continue to provide data needed to
inform immunization policy makers, medical and immunization providers, and the public about the safety
of COVID-19 vaccination.
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Research in context
Evidence before this study
‘We searched PubMed for articles published through July 12, 2021, using the terms (“BNT162b2”or
“mRNA-1273” or “mRNA COVID-19 vaccine”) AND (“reactogenicity” or “side-effects” or “adverse
effects” or “health impact”) not restricted by language or type of publication. Among 100 results,
publications describing the health impacts following vaccination by BNT162b2 ormRNA-1273 are
limited. Available literature from the United States included reports of manufacturer-sponsored phase 1-3
clinical trials. Additionally, we found seven published articles from the United States, one published
article from United Kingdom and two preprints from the United States investigating reactogenicity and
adverse events in mRNA vaccination. These articles discussed reactogenicity and adverse events
following mRNA vaccination. No study included the period through June 2021.
Added value of this study
In this large, observational study, we assessed reactogenicity, health impact, and adverse events reported
following mRNA COVID-19 vaccination during the first six months of the U.S. vaccination program.We
found that reported reactions to mRNA vaccination were mostly mild in severity and transient in duration,
and the great majority of reports were non-serious. Reactions and health impact were reported more
frequently in females compared to males, and in individuals aged <65 years compared to older
individuals. Health impact information for adults from v-safe is presented here for the first time. Deaths,
overall and for specific causes by age, were reported.
Implications of all the available evidence
The findings from complementary surveillance systems from the first six months of mRNA vaccination in
‘the United States are consistent with pre-authorization clinical trials and early post-authorization reports.
Mild-to-moderate transient reactogenicity should be anticipated, particularly among lyounger recipients
and female recipients. |. As these data inform immunization policy recommendations and clinical
considerations, the federal monitoring system continues to update the benefit-risk balance of vaccine
‘Commented
[BR(30]:
Suggest being
more specific,
eg.,
‘younger recipients, females.
Office of Science
2021-08-11 11:01:00
Commented [RH(31R30]: edited
Rosenblum, Hannah (CDC)
2021-08-17 14:37:00
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recommendations, particularly in the setting of the association of specific serious adverse events and
COVID-19 vaccination.
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Table 1: Characteristics of reports received and processed by Vaccine Adverse Events Reporting System
(VAERS) for mRNA COVID-19 vaccines—December 14, 2020–June 14, 2021
Both mRNA vaccines† BNT162b2 vaccine mRNA-1273 vaccine
(n=340,522) (n=164,669) (n=175,816)
Reports
Non-serious adverse event reports 313,499 (92·1) 150,486 (91·4) 162,977 (92·7)
Serious reports, including death 27,023 (7·9) 14,183 (8·6) 12,839 (7·3)
Serious, non-death adverse event reports 22,527 (6·6) 12,078 (7·3) 10,448 (5·9)
Death 4,496 (1·3) 2,105 (1·3) 2,391 (1·4)
Sex
Female 246,085 (72·3) 116,587 (70·8) 129,475 (73·6)
Male 88,311 (25·9) 45,157 (27·4) 43,140 (24·5)
Unknown 6,126 (1·8) 2,925 (1·8) 3,201 (1·8)
Age (years)
16–17 6,874 (2·0) 3,283 (2·0) 3,591 (2·0)
18–49 154,171 (45·3) 76,385 (46·4) 77,773 (44·2)
50–64 84,949 (24·9) 40,367 (24·5) 44,572 (25·4)
65–74 49,755 (14·6) 20,048 (12·2) 29,702 (16·9)
75–84 21,418 (6·3) 9,021 (5·5) 12,392 (7·1)
≥85 7,595 (2·2) 3,564 (2·2) 4,027 (2·3)
Unknown 15,760 (4·6) 12,001 (7·3) 3,759 (2·1)
Race/Ethnicity
Hispanic/Latino 23,480 (6·9) 11,217 (6·8) 12,260 (7·0)
Non-Hispanic
White 169,877 (49·9) 73,398 (44·6) 96,469 (54·9)
Black 10,446 (3·1) 5,104 (3·1) 5,342 (3·0)
Asian 10,172 (3·0) 5,038 (3·1) 5,131 (2·9)
American Indian or Alaska Native 1,414 (0·4) 615 (0·4) 799 (0·5)
Native Hawaiian or Other Pacific Islander 441 (0·1) 209 (0·1) 232 (0·1)
Multiple races 3,542 (1·0) 1,578 (1·0) 1,964 (1·1)
Other races 1,684 (0·5) 808 (0·5) 876 (0·5)
Unknown race 2,593 (0·8) 1,422 (0·9) 1,171 (0·7)
Unknown ethnicity
White 28,787 (8·5) 15,497 (9·4) 13,289 (7·6)
Black 4,189 (1·2) 2,524 (1·5) 1,662 (1·0)
Asian 2,435 (0·7) 1,396 (0·9) 1,039 (0·6)
American Indian or Alaska Native 724 (0·2) 348 (0·2) 375 (0·2)
Native Hawaiian or Other Pacific Islander 105 (0·03) 56 (0·03) 49 (0·03)
Multiple races 590 (0·2) 301 (0·2) 289 (0·2)
Other races 4,709 (1·4) 2,838 (1·7) 1,870 (1·1)
Unknown race and ethnicity 75,334 (22·1) 42,320 (25·7) 32,999 (18·8)
Signs or symptoms most frequently reported, non-
serious*
Headache 64,064 (20·4) 30,907 (20·5) 33,154 (20·3)
Fatigue 52,048 (16·6) 24,805 (16·5) 27,241 (16·7)
Pyrexia 51,023 (16·3) 22,185 (14·7) 28,837 (17·7)
Chills 49,234 (15·7) 21,638 (14·4) 27,595 (16·9)
Pain 47,745 (15·2) 21,506 (14·3) 26,238 (16·1)
Nausea 37,333 (11·9) 18,066 (12·0) 19,267 (11·8)
Dizziness 37,257 (11·9) 20,307 (13·5) 16,950 (10·4)
Pain in extremity 31,753 (10·1) 14,098 (9·4) 17,653 (10·8)
Injection site pain 28,949 (9·2) 10,462 (7·0) 18,487 (11·3)
Injection site erythema 22,351 (7·1) 2,991 (2·0) 19,360 (11·9)
Signs or symptoms most frequently reported, serious*
Dyspnea 4,175 (15·4) 2,210 (15·6) 1,965 (15·3)
Death‡ 3,802 (14·1) 1,753 (12·4) 2,039 (15·9)
Pyrexia 2,986 (11·0) 1,469 (10·4) 1,517 (11·8)
Fatigue 2,608 (9·7) 1,395 (9·8) 1,213 (9·4)
Headache 2,567 (9·5) 1,360 (9·6) 1,207 (9·4)
Chest pain 2,300 (8·5) 1,310 (9·2) 990 (7·7)
Nausea 2,228 (8·2) 1,160 (8·2) 1,068 (8·3)
Pain 2,222 (8·2) 1,195 (8·4) 1,027 (8·0)
Asthenia 2,194 (8·1) 1,084 (7·6) 1,110 (8·6)
Dizziness 2,069 (7·7) 1,111 (7·8) 958 (7·5)
Data are n (%).
*Symptoms refers to MedDRA preferred terms (PTs) and are ordered by most frequently reported for both vaccines. MedDRA PTs are not
mutually exclusive.
†Total includes reports without a vaccine manufacturer listed.
‡Not all reports of death were coded with the MedDRA PT of ‘death’
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Table 2: Frequency and reporting rates of adverse events of special interest reported to Vaccine Adverse
Event Reporting System (VAERS) by recipients of mRNA COVID-19 vaccine—December 14, 2020–June 14,
2021
Both mRNA vaccines BNT162b2 vaccine mRNA-1273 vaccine
n Reports per
million doses* n Reports per million
doses† n Reports per
million doses‡
Non-serious adverse event reports 313,499 1,049·2 150,486 900·2 162,977 1,238·1
Serious reports, including death 27,023 90·4 14,183 84 8 12,839 97·5
Serious, non-death adverse event reports 22,527 75·4 12,078 72 2 10,448 79·4
Reports§ of adverse events of special interest**
COVID-19 9,344 31·3 7,184 43 0 2,160 16·4
Coagulopathy†† 4,320 14·5 2,343 14 0 1,977 15·0
Seizure 2,733 9·1 1,478 8·8 1,255 9·5
Stroke‡‡ 1,937 6·5 981 5·9 955 7·3
Bells’ Palsy 1,918 6·4 1,057 6·3 861 6·5
Anaphylaxis 1,639 5·5 972 5·8 667 5·1
Myopericarditis 1,307 4·4 813 4·9 494 3·8
Acute Myocardial Infarction 1,118 3·7 610 3·6 508 3·9
Appendicitis 383 1·3 258 1·5 125 1·0
Guillain-Barré Syndrome 293 1·0 154 0·9 139 1·1
Multisystem Inflammatory Syndrome in Adults 119 0·4 60 0·4 59 0·4
Transverse Myelitis 98 0·3 55 0·3 43 0·3
Narcolepsy 21 0·1 12 0·1 9 0·1
*298,792,852 doses of mRNA vaccine were administered in the study period.
†167,177,332 doses of BNT162b2 vaccine were administered in the study period.
‡131,639,515 doses of mRNA-1273 vaccine were administered in the study period.
§These represent reports, not confirmed by case definition.
**Reported death is an adverse event of special interest but counts appear in following tables. Events are not mutually exclusive.
††Coagulopathy is an aggregate term capturing three specific adverse events: 1) thrombocytopenia, 2) deep venous
thrombosis/pulmonary embolism, and 3) disseminated intravascular coagulopathy.
‡‡No vaccine manufacturer was provided for one report of stroke.
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Table 3: Characteristics of deaths reported to Vaccine Adverse Event Reporting System (VAERS) by
recipients of mRNA COVID-19 vaccine—December 14, 2020–June 14, 2021
Both mRNA vaccines BNT162b2 vaccine mRNA-1273 vaccine
(n=4,472*) (n=2,087) (n=2,385)
n (%) Reports per
million doses† n (%) Reports per
million doses‡ n (%) Reports per million
doses §
Sex
Female 1,906 (42·6) 6·4 918 (44·0) 5·5 988 (41·4) 7·5
Male 2,486 (55·6) 8·3 1,117 (53·5) 6·7 1,369 (57·4) 10·4
Unknown 80 (1·8) 0·3 52 (2·5) 0·3 28 (1·2) 0·2
Age (years)
16–17 6 (0·1) 0·02 6 (0·3) 0·04 ·· ··
18–29 51 (1·1) 0·2 27 (1·3) 0·2 24 (1·0) 0·2
30–39 94 (2·1) 0·3 50 (2·4) 0·3 44 (1·8) 0·3
40–49 151 (3·4) 0·5 74 (3·5) 0·4 77 (3·2) 0·6
50–59 328 (7·3) 1·1 132 (6·3) 0·8 196 (8·2) 1·5
60–69 765 (17·1) 2·6 354 (17·0) 2·1 411 (17·2) 3·1
70–79 1,118 (25·0) 3·7 497 (23·8) 3·0 621 (26·0) 4·7
80–89 1,128 (25·2) 3·8 529 (25·3) 3·2 599 (25·1) 4·6
≥90 637 (14·2) 2·1 302 (14·5) 1·8 335 (14·0) 2·5
Unknown 194 (4·3) 0·6 116 (5·6) 0·7 78 (3·3) 0·6
*Of 4,496 deaths, 24 were excluded as they could not be confirmed or were duplicate reports upon review.
†298,792,852 doses of mRNA vaccine were administered in the study period.
‡167,177,332 doses of BNT162b2 vaccine were administered in the study period.
§131,639,515 doses of mRNA-1273 vaccine were administered in the study period.
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Table 4: Most common causes of death among reports received and processed by Vaccine Adverse Event
Reporting System (VAERS) following mRNA COVID-19 vaccination (n=4,472)—December 14, 2020—June
14, 2021
Death or autopsy certificate available [No death certificate or autopsy available
BothmRNA BNTI6b2_mRNAI273 BothmRNA BNTIGH2 wRNAATS
ICD.10 Major Group vaccines vaccine vaccine vaccines vaccine vaccine
808) Geto) 407) 3.668) 1,686) 1.978)
‘All reported deaths
Diseases of the heart 376 (46-5) 161(401) 215 (52-8) (17-0) -296(17-6) 326(16-5)
COVID-19 disease 102 (12-6) 62055) 409-8) 31787) 178(10-6) 1397-0)
Other @) = 380-3004) 14168 6840) BG)
Cerebrovascular diseases 36-6) 28(7-0) 2561) 207 (5-6) 101 (6-0) 106 (5-4)
Dementia 46D 2060 2162) 902) 302 603)
(Chronic lower respiratory diseases BE) = «174 1E-D 2908) 1006 190-0)
Malignant neoplasms 76) 56D LEH a9) 225) 2603)
‘Unknown/unclear 273) 922) 18 (4-4) 1,984 (54-1) 844(50-1) 1,14067-6)
Septicemia BeE® 26H 107 neo 4728) 2503)
Influenza and pneumonia RED BAN 40-0 BG) = 261) G1)
‘Accidents/unintentional injuries ud) 307 82-0) noo 80-5) 1407)
Renal disease sao say 307) 2507) 7104 189)
Hematologic disease, other than malignancy 7 (0-9) 5a -2@5) 1905) 905) 105)
Pueumonitis due to solids and liquids 6on 30D 307) 802) 503) 32),
Diabetes mellitus 405) 102 307 6@2 402 20)
(Chronic liver disease and cinhosis 405) 30D 10) 702) 402 32)
Intentional self-harm 11) 1@2) 00-0) 150-4) 80-5) 70-4)
Data aren (%).
23
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‘Commented [RH(32]: Note this is the 5® VAERS table
(compared to 2 v-safe and 1 v-safe figure) and the 3" table
— hee oi R9 ==
Within 7 days Within 42 days | Within days Within 42 days Within Tdays Within 42 days Within Tdays Within#2 brye—
Age
(years)
65-74 (343.2 2,059.4, 457 878 207 385 250 493,
285 26014 15,6083, 437 980 202 448 BS 332,
*calculated from Abara paper per 10,000,000
** Abara paper is 15-24. Age 15 was not included in this paper
‘Need 42 day columns?
24
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Table 5: Demographic characteristics of v-safe participants reporting receipt of mRNA COVID-19 vaccine
and completing at least one health survey 0-7 days after vaccination—December 14, 2020–June 14, 2021
Both mRNA vaccines BNT162b2 vaccine mRNA-1273 vaccine
Characteristics Dose 1 Dose 2 Dose 1 Dose 2
(n = 7,914,583) n=3,455,778 n=2,920,526 n= 3,319,737 n=2,753,894
Sex
Female 4,975,209 (62·9) 2,150,068 (62·2) 1,861,599 (63·7) 2,073,542 (62·5) 1,779,200 (64·6)
Male 2,860,738 (36·1) 1,272,011 (36·8) 1,032,941 (35·4) 1,210,622 (36·5) 947,612 (34·4)
Other 8,872 (0·1) 4,027 (0·1) 3,464 (0·1) 3,443 (0·1) 2,947 (0·1)
Unknown 69,764 (0·9) 29,672 (0·9) 22,522 (0·8) 32,130 (1·0) 24,135 (0·9)
Age (years)
16–17 73,347 (0·9) 63,865 (1·8) 38,530 (1·3) 946 (0·03) 473 (0·02)
18–49 3,791,839 (47·9) 1,726,465 (50·0) 1,431,627 (49·0) 1,505,760 (45·4) 1,219,210 (44·3)
50–59 1,500,981 (19·0) 653,799 (18·9) 574,422 (19·7) 627,214 (18·9) 531,200 (19·3)
60–64 739,381 (9·3) 315,404 (9·1) 279,350 (9·6) 316,768 (9·5) 270,831 (9·8)
65–74 1,344,721 (17·0) 516,227 (14·9) 452,928 (15·5) 643,663 (19·4) 557,279 (20·2)
≥75 464,314 (5·9) 180,018 (5·2) 143,669 (4·9) 225,386 (6·8) 174,901 (6·4)
Race/Ethnicity
Hispanic 782,301 (9·9) 346,197 (10·0) 288,263 (9·9) 316,460 (9·5) 256,185 (9·3)
Non-Hispanic
White 4,701,715 (59·4) 2,059,560 (59·6) 1,896,823 (64·9) 1,979,056 (59·6) 1,830,413 (66·5)
Black 443,938 (5·6) 202,598 (5·9) 176,164 (6·0) 178,981 (5·4) 153,667 (5·6)
Asian 467,932 (5·9) 215,713 (6·2) 196,173 (6·7) 154,498 (4·7) 138,793 (5·0)
American Indian or Alaska Native 27,899 (0·4) 11,161 (0·3) 9,194 (0·3) 13,486 (0·4) 11,410 (0·4)
Native Hawaiian or Other Pacific Islander 19,393 (0·2) 8,500 (0·2) 7,373 (0·3) 7,689 (0·2) 6,664 (0·2)
Multiple races 110,326 (1·4) 50,954 (1·5) 46,129 (1·6) 41,977 (1·3) 38,772 (1·4)
Other races 42,230 (0·5) 19,252 (0·6) 16,757 (0·6) 15,885 (0·5) 13,880 (0·5)
Unknown race 23,420 (0·3) 10,249 (0·3) 9,090 (0·3) 9,502 (0·3) 8,270 (0·3)
Unknown ethnicity*
White 115,766 (1·5) 48,084 (1·4) 38,674 (1·3) 52,143 (1·6) 42,070 (1·5)
Black 26,865 (0·3) 11,602 (0·3) 8,570 (0·3) 11,993 (0·4) 8,406 (0·3)
Asian 33,146 (0·4) 14,134 (0·4) 11,844 (0·4) 11,356 (0·3) 9,153 (0·3)
American Indian or Alaska Native 3,142 (0·04) 1,206 (0·03) 848 (0·03) 1,582 (0·05) 1,151 (0·04)
Native Hawaiian or Other Pacific Islander 1,945 (0·02) 815 (0·02) 659 (0·02) 800 (0·02) 613 (0·02)
Multiple races 6,370 (0·1) 2,902 (0·1) 2,408 (0·1) 2,478 (0·1) 2,041 (0·1)
Other races 13,148 (0·2) 5,681 (0·2) 4,528 (0·2) 5,414 (0·2) 4,263 (0·2)
Unknown race and ethnicity* 129,647 (1·6) 56,481 (1·6) 45,410 (1·6) 54,969 (1·7) 44,340 (1·6)
Unavailable† 965,400 (12·2) 390,689 (11·3) 161,619 (5·5) 461,468 (13·9) 183,803 (6·7)
Pregnant at time of vaccination 86,801 (1·1) 39,884 (1·2) 39,163 (1·3) 25,255 (0·8) 25,428 (0·9)
Pregnancy test positive after vaccination 27,370 (0·3) 1,548 (0·04) 11,677 (0·4) 4,009 (0·1) 10,199 (0·4)
Data are n (%).
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“Unknown indicates that v-safe participants selected unknown or preferred not to say.
Unavailable refers to information that was not collected or missing in v-safe.
Table 6: Reported local and systemic reactions*, and reported health impact following mRNA COVID-19
vaccines reported days 0-7 after vaccination to v-safe, by manufacturer and dose—December 14, 2020 — June
14, 2021
Both mRNA vaccines BNTI62%2 vaccine mRNA-1273 vaccine
Dose ‘Dose 2 ‘Dose 1 ‘Dose 2 Dose Dose 2
6.715515) (05,674,420) (03,455,778) (2.920526) (3,319,737) (02,753,894)
‘Anyinjection site reaction 4,644,989 (68-6) 4068-47 (71-7) 2,212,051 (64-0) 1,908.124(65-3) 2.432.938 033) 2,160,323 (78-4)
Injection site pain 4,488,402 (66-2) 3,890,848 (68-6) 2,140,843 (61-9) 1,835,398 (62-8) 2,347,559(707) 2,055,450 (74-6)
‘Swelling 703,790 (10-4) 976946(17-2) 246230(71) 309,718 (10-6) 457,560 (13-8) (667.228 042)
Redness 353,788 (5-2) 640,739(11-3) 116.1084) 167,127(5-7) 237,680 (7-2) 47361217.)
Itching 316,076 (5-9) 605,633 (107) 14559642) 191.1325) 230.4806 9) 414501 (15-1)
Any systemic reaction 3,573,429 62-1) 40018920 708) 1,771,509(51-3) 1,931,643 (66-1) 1,801,920643) 2.087277 05-8)
Fatigue 2,295,205 (33-9) 3,158,299 (55-7) 1,127,904 2-6) 1,475,646 (50-5) 1,167,301 52) 1,682,653 (61-1)
26
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Headache 1,831,471 (27·0) 2,623,721 (46·2) 893,992 (25·9) 1,189,444 (40·7) 937,479 (28·2) 1,434,277 (52·1)
Myalgia 1,423,336 (21·0) 2,478,170 (43·7) 653,821 (18·9) 1,085,365 (37·2) 769,515 (23·2) 1,392,805 (50·6)
Chills 631,546 (9·3) 1,680,185 (29·6) 263,617 (7·6) 642,856 (22·0) 367,929 (11·1) 1,037,329 (37·7)
Fever 642,092 (9·5) 1,679,577 (29·6) 274,650 (7·9) 656,454 (22·5) 367,442 (11·1) 1,023,123 (37·2)
Joint pain 642,006 (9·5) 1,440,927 (25·4) 285,812 (8·3) 591,877 (20·3) 356,194 (10·7) 849,050 (30·8)
Nausea 562,273 (8·3) 901,103 (15·9) 267,160 (7·7) 384,525 (13·2) 295,113 (8·9) 516,578 (18·8)
Diarrhea 383,576 (5·7) 419,044 (7·4) 190,542 (5·5) 198,618 (6·8) 193,034 (5·8) 220,426 (8·0)
Abdominal pain 233,511 (3·4) 359,107 (6·3) 113,872 (3·3) 158,251 (5·4) 119,639 (3·6) 200,856 (7·3)
Rash 85,766 (1·3) 99,878 (1·8) 41,565 (1·2) 42,662 (1·5) 44,201 (1·3) 57,216 (2·1)
Vomiting 55,710 (0·8) 91,727 (1·6) 25,336 (0·7) 36,761 (1·3) 30,374 (0·9) 54,966 (2·0)
With reported health
impact* 808,963 (11·9) 1,821,421 (32·1) 361,834 (10·5) 740,529 (25·4) 447,129 (13·5) 1,080,892 (39·2)
Unable to do normal activity 658,330 (9·7) 1,501,679 (26·5) 290,207 (8·4) 598,584 (20·5) 368,123 (11·1) 903,095 (32·8)
Unable to work 305,709 (4·5) 911,366 (16·1) 135,063 (3·9) 360,411 (12·3) 170,646 (5·1) 550,955 (20·0)
Reported medical care 56,647 (0·8) 53,077 (0·9) 27,358 (0·8) 25,568 (0·9) 29,289 (0·9) 27,509 (1·0)
Telehealth 19,562 (0·3) 19,770 (0·3) 9,318 (0·3) 9,238 (0·3) 10,244 (0·3) 10,532 (0·4)
Clinic 18,671 (0·3) 16,793 (0·3) 9,109 (0·3) 8,487 (0·3) 9,562 (0·3) 8,306 (0·3)
Emergency visit 9,907 (0·1) 8,907 (0·2) 5,087 (0·1) 4,494 (0·2) 4,820 (0·1) 4,413 (0·2)
Hospitalization 1,896 (0·03) 2,053 (0·04) 915 (0·03) 1,001 (0·03) 981 (0·03) 1,052 (0·04)
Data are n (%).
*Reports of local and systemic reactions, and reports of health impact are not mutually exclusive.
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[Figure1: Percent distribution of the 10 leading causes of death, by age, among reported deaths with death certificate or autopsy to Vaccine Adverse Event Reporting ‘Commented [RH(33]: make supplemental or delete?
‘System (VAERS) December 14, 2020—June 14, 2021 following mRNA vaccination Data is captured in supplemental table 2
Rosenblum, Hannah (CDC)
2021-09-08 16:03:00
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Figure 2: Local and systemic reactions’ to mRNA COVID-19 vaccine reported in v-safe, by manufacturer, dose, days after vaccination, and severity?
BNT162b2 vaccine ‘BNT162b2 vaccine
Dose 1 Dose 2
100 100
0
80
co
30
0
30
> :
— nil ‘lich liswlt0123456701234567012345670123 01234567012345670123456701
z
2
a
z
jecimSie
Fate
==
Hiadacke
=
Male Gill’
Jom
Pah
euigsie
Fale
lade
Meh
at
Pas =
Days since last dose Days since last dose
mRNA-1273 vaccine smRNA1273 vaccine
Dose 1 Dose2
100 100 Mild WModerate. Severe
Days since last dose Days since last dose
*Top five reactions determined by reported frequency after second dose of both mRNA COVID-19 vaccines in v-safe, excluding fever because it was not rated mild, moderate, or severe.
‘Mild was defined as “noticeable symptoms but they aren't a problem’, moderate was defined as “symptoms that limit normal activities, and severe symptoms “make normal daily activities difficult
or impossible”
29
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Supplemental Table 1: mRNA COVID-19 vaccine doses administered in the United States—December 14, 2020–June 14, 2021
Both mRNA vaccines† BNT162b2 vaccine† mRNA-1273 vaccine†
Characteristics
(n=298,792,852) (n=167,177,332) (n=131,639,515)
Sex
Female 155,969,573 (53·2) 86,507,992 (53·5) 69,461,582 (52·8)
Male 134,373,958 (45·8) 73,768,602 (45·6) 60,605,356 (46·1)
Unknown 2,868,979 (1·0) 1,452,344 (0·9) 1,416,634 (1·1)
Age (years)
16–17* 5,506,763 (1·8) 5,365,855 (3·2) 140,908 (0·1)
18–49 126,288,626 (42·3) 74,999,327 (44·9) 51,289,299 (39·0)
50–64 79,207,752 (26·5) 43,595,972 (26·1) 35,611,780 (27·1)
65–74 51,699,307 (17·3) 25,402,217 (15·2) 26,297,090 (20·0)
75–84 27,731,181 (9·3) 13,555,128 (8·1) 14,176,053 (10·8)
≥85 8,359,223 (2·8) 4,248,648 (2·5) 4,110,575 (3·1)
Unknown 23,995 (0·01) 10,185 (0·01) 13,810 (0·01)
Race/Ethnicity
Hispanic 31,599,632 (10·8) 17,964,345 (11·1) 13,635,287 (10·4)
Non-Hispanic
White 112,698,875 (38·4) 61,996,607 (38·3) 50,702,268 (38·6)
Asian 11,789,429 (4·0) 7,258,033 (4·5) 4,531,396 (3·4)
Black 16,848,436 (5·7) 9,665,586 (6·0) 7,182,849 (5·5)
American Indian or Alaska Native 1,738,938 (0·6) 842,263 (0·5) 896,674 (0·7)
Native Hawaiian or Other Pacific Islander 508,285 (0·2) 295,634 (0·2) 212,651 (0·2)
Multiple races 8,856,800 (3·0) 5,037,828 (3·1) 3,818,972 (2·9)
Other races 6,949,404 (2·4) 4,161,353 (2·6) 2,788,051 (2·1)
Unknown race and ethnicity 102,227,532 (34·9) 54,511,493 (33·7) 47,716,039 (36·3)
Data are n (%).
*mRNA-1273 vaccine was not authorized for individuals <18 years during this period, reported mRNA-1273 doses are either from clinical trials or were administered or reported in error
†Totals reflect the number of doses in age categories. Missing doses for sex and race/ethnicity are due to certain jurisdictions that report data in aggregate.
Supplemental Table 2: Causes of death among reported deaths to Vaccine Adverse Event Reporting System (VAERS) December 14, 2020–June 14, 2021 following mRNA
vaccination, by age
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‘Commented [RH(34]: Combine 16-24 and 25-34? n=9
Rosenblum, Hannah (CDC)
2021-08-27 21:56:00
‘Reports of death with death cert or
autopsy an | 16-24 25.34 35-44 45-54 55-64 65-74 75-84 85+
ICD-10 Major Group gos | ad a5 24 237 n=101 ll 202 264
E a % |o % |o %|o % |o % |[n % |n % | a %
Diseases of the heart ae f1 250f 2 400] 10 a17[ 21 sos} so 495] 98 573] 91 450] 103 390
COVID-19 disease 1o2)1 20) 1 20] 2 83) 2 s4] m1 09] 19 a4) 32 158] 34 129
Cerebrovascular diseases slo of o of o of 4 ws] s 79/ 8 47/13 64] 20 76
Other es]}o of] 1 20] s 28] 2 sa] 10 99/11 64] is 74] 24 94
Influenza and pneumonia nio of 0 of 2 83] 0 o] 2 20/ 4 23) 7 35) 7 27
‘Malignant neoplasms alo of o of o of 2 sa] s sof 2 12] 8 40] 10 38
Septicemia zalo of o of o of 1 27) 2 20] 2 12) 6 30} 2 45
Chronic lower respiratory diseases alo of 0 of o of o of 2 20/1 64] 4 20) 1 42
Dementia, inc Alzheimer's, Parkinson'sdz 41/0 0] 0 of 0 0] 0 of 1 10] 1 06) 7 35) 32 124
‘Accidents/unintentional injuries ufo of o of 1 42] 0 o] 2 20f 2 12) 3 as) 3 a4
‘Renal dz, incl nephritis and chronic dz s}o of o of o of 1 27] o o] 3 1sf 3 as} 1 04
‘Hematologic dz, other than malignancy 7/0 of 0 of o of 1 27) 3 30f 0 of 1 os} 2 o8
Intentional self-harm 1f1 20] 0 of o of o o| o o] 0 of 0 of o o
Pneumonitis due to solids and liquids 6}o of 0 of o of o o] 1 10} o of 3 as} 2° og
(Chronic liver disease and cisthosis, 4}o of 1 20/ o of o o] 1 10] 1 o6] 1 os} 0 0
Diabetes mellitus 4fo of 0 of 1 42] 0 o| o o] 2 12] 1 os} 0 0
‘Unknown/unclear ali aol o of 3 ws] 3 sil 3 30/7 41f 7 35] 3° 44
‘Supplemental Table 3: Causes and impressions of death among reported deaths to Vaccine Adverse Event Reporting System (VAERS) December 14, 2020-June 14, 2021
following mRNA vaccination
31
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ICD-10 Major Group and impression All reports of death Reported deaths with death
certificate or autopsy
All reported deaths, n 4,472 808
Diseases of the heart 998 (22.3) 376 (46.5)
Aortic dissection, aneurysm or aortitis 13 (0.3) 7 (0.9)
Arrhythmia 42 (0.9) 18 (2.2)
Atherosclerotic cardiovascular or hypertensive cardiovascular disease 129 (2.9) 98 (12.1)
Cardiac arrest 321 (7.2) 79 (9.8)
Cardiomyopathy or hypertrophy 17 (0.4) 12 (1.5)
Heart failure 104 (2.3) 47 (5.8)
Myocardial infarction 247 (5.5) 87 (10.8)
Myocarditis 4 (0.1) 0 (0.0)
Pulmonary embolism 84 (1.9) 17 (2.1)
Other cardiac cause 37 (0.8) 11 (1.4)
COVID-19 disease 419 (9.4) 102 (12.6)
Cerebrovascular diseases 260 (5.8) 53 (6.6)
Other 209 (4.7) 68 (8.4)
Disseminated herpes zoster 2 (0.04) 1 (0.1)
Drug overdose/intoxication 7 (0.2) 5 (0.6)
Failure to thrive 9 (0.2) 9 (1.1)
Gastrointestinal* 36 (0.8) 8 (1.0)
Hemorrhage/Hemorrhagic shock 4 (0.1) 2 (0.2)
Metabolic derangement 4 (0.1) 1 (0.1)
Multiorgan failure 28 (0.6) 7 (0.9)
Natural 2 (0.04) 2 (0.2)
Neurologic† 28 (0.6) 6 (0.7)
Obesity 2 (0.04) 2 (0.2)
Respiratory failure 63 (1.4) 22 (2.7)
Vaccine related‡ 4 (0.1) 3 (0.4)
Influenza and pneumonia 135 (3.0) 22 (2.7)
Malignant neoplasms 95 (2.1) 27 (3.3)
Septicemia 95 (2.1) 23 (2.8)
Chronic lower respiratory diseases 57 (1.3) 28 (3.5)
Dementia 50 (1.1) 41 (5.1)
Accidents/unintentional injuries 33 (0.7) 11 (1.4)
Renal disease 33 (0.7) 8 (1.0)
Hematologic disease, other than malignancy 26 (0.6) 7 (0.9)
Intentional self-harm 16 (0.4) 1 (0.1)
Pneumonitis due to solids and liquids 14 (0.3) 6 (0.7)
Chronic liver disease and cirrhosis 11 (0.2) 4 (0.5)
Diabetes mellitus 10 (0.2) 4 (0.5)
Unknown/unclear 2,011 (45.0) 27 (3.3)
†Data are n (%) unless otherwise stated.
*Gastrointestinal includes gastrointestinal bleeding, bowel obstruction/perforation, mesenteric ischemia, pancreatitis.
†Neurologic includes amyotrophic lateral sclerosis, encephalopathy, hydrocephalus, Guillain-Barré syndrome, seizure.
‡Vaccine related includes systemic inflammatory response syndrome from vaccine reaction, anaphylaxis post-COVID-19 vaccination
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33
Supplemental Table 4: Local and systemic reactions* 0–7 days after vaccination by sex, age, and dose number, reported in v-safe—December 14, 2020–
June 14, 2021
Female Male <65 years ≥65 years
Dose 1 Dose 2 Dose 1 Dose 2 Dose 1 Dose 2 Dose 1 Dose 2
(n=4,223,610) (n=3,640,799) (n=2,482,633) (n=1,980,553) (n=5,210,221) (n=4,345,643) (n=1,565,294) (n=1,328,777)
Any injection site reaction 3,095,194 (73·3) 2,792,488 (76·7) 1,498,108 (60·3) 1,235,278 (62·4) 3,835,618 (73·6) 3,290,206 (75·7) 809,371 (51·7) 778,241 (58·6)
Injection site pain 2,989,733 (70·8) 2,666,734 (73·3) 1,448,440 (58·3) 1,184,914 (59·8) 3,728,795 (71·6) 3,179,024 (73·2) 759,607 (48·5) 711,824 (53·6)
Swelling 539,793 (12·8) 771,962 (21·2) 154,980 (6·2) 194,033 (9·8) 604,868 (11·6) 812,126 (18·7) 98,922 (6·3) 164,820 (12·4)
Redness 283,345 (6·7) 529,175 (14·5) 66,134 (2·7) 104,933 (5·3) 295,413 (5·7) 512,516 (11·8) 58,375 (3·7) 128,223 (9·6)
Itching 299,407 (7·1) 504,016 (13·8) 72,095 (2·9) 95,356 (4·8) 309,607 (5·9) 466,319 (10·7) 66,469 (4·2) 139,314 (10·5)
Any systemic reaction 2,444,362 (57·9) 2,752,592 (75·6) 1,088,296 (43·8) 1,226,561 (61·9) 2,972,931 (57·1) 3,237,621 (74·5) 600,498 (38·4) 781,299 (58·8)
Fatigue 1,624,531 (38·5) 2,221,361 (61·0) 643,206 (25·9) 904,556 (45·7) 1,941,979 (37·3) 2,588,541 (59·6) 353,226 (22·6) 569,758 (42·9)
Headache 1,349,155 (31·9) 1,906,337 (52·4) 460,786 (18·6) 690,138 (34·8) 1,595,091 (30·6) 2,226,046 (51·2) 236,380 (15·1) 397,675 (29·9)
Myalgia 954,469 (22·6) 1,724,474 (47·4) 450,562 (18·1) 726,994 (36·7) 1,219,190 (23·4) 2,085,722 (48·0) 204,146 (13·0) 392,448 (29·5)
Chills 451,583 (10·7) 1,202,364 (33·0) 172,283 (6·9) 459,577 (23·2) 542,285 (10·4) 1,426,710 (32·8) 89,261 (5·7) 253,475 (19·1)
Fever 446,178 (10·6) 1,182,201 (32·5) 187,713 (7·6) 478,912 (24·2) 565,804 (10·9) 1,449,504 (33·4) 76,288 (4·9) 230,073 (17·3)
Joint pain 444,630 (10·5) 1,023,525 (28·1) 188,846 (7·6) 400,963 (20·2) 539,196 (10·3) 1,214,624 (28·0) 102,810 (6·6) 226,303 (17·0)
Nausea 447,766 (10·6) 728,730 (20·0) 106,872 (4·3) 161,455 (8·2) 500,782 (9·6) 794,450 (18·3) 61,491 (3·9) 106,653 (8·0)
Diarrhea 272,890 (6·5) 313,252 (8·6) 106,079 (4·3) 101,107 (5·1) 323,773 (6·2) 352,077 (8·1) 59,803 (3·8) 66,967 (5·0)
Abdominal pain 179,210 (4·2) 283,422 (7·8) 50,991 (2·1) 71,115 (3·6) 203,575 (3·9) 316,165 (7·3) 29,936 (1·9) 42,942 (3·2)
Rash 65,498 (1·6) 79,092 (2·2) 19,193 (0·8) 19,735 (1·0) 70,985 (1·4) 79,913 (1·8) 14,781 (0·9) 19,965 (1·5)
Vomiting 43,998 (1·0) 75,650 (2·1) 10,936 (0·4) 14,915 (0·8) 49,483 (0·9) 81,733 (1·9) 6,227 (0·4) 9,994 (0·8)
Data are n (%).
*Reports of local and systemic reactions are not mutually exclusive.
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Supplemental Table 5: Most common local and systemic reactions* to mRNA COVID-19 vaccine reported in
v-safe, by dose and severity,† 0-7 days after vaccination with BNT162b2 vaccine
Dose 1 Dose 2
Day All, n Severe Moderate Mild All, n Severe Moderate Mild
0 2,272,335 2,533 (0·1) 80,358 (3·5) 599,511 (26·4) 1,766,510 4,359 (0·2) 94,156 (5·3) 503,779 (28·5)
1 2,545,271 18,827 (0·7) 334,755 (13·2) 1,289,293 (50·7) 2,027,330 48,810 (2·4) 453,726 (22·4) 885,434 (43·7)
2 2,545,434 4,356 (0·2) 62,838 (2·5) 565,455 (22·2) 2,116,614 10,391 (0·5) 126,741 (6·0) 680,408 (32·1)
3 2,507,344 2,119 (0·1) 26,602 (1·1) 216,785 (8·6) 2,067,908 3,332 (0·2) 43,037 (2·1) 336,222 (16·3)
4 2,436,977 1,420 (0·1) 16,710 (0·7) 102,077 (4·2) 2,028,926 1,820 (0·1) 20,548 (1·0) 149,408 (7·4)
5 2,332,032 1,138 (0·05) 11,965 (0·5) 60,401 (2·6) 2,000,426 1,272 (0·1) 12,719 (0·6) 73,486 (3·7)
6 2,249,409 909 (0·04) 8,901 (0·4) 40,597 (1·8) 2,000,472 1,106 (0·1) 11,008 (0·6) 46,707 (2·3)
Injection site
pain
7 2,198,611 768 (0·03) 7,783 (0·4) 32,967 (1·5) 2,067,201 1,557 (0·1) 14,159 (0·7) 44,322 (2·1)
0 2,272,335 7,280 (0·3) 79,232 (3·5) 193,192 (8·5) 1,766,510 11,293 (0·6) 98,802 (5·6) 185,051 (10·5)
1 2,545,271 35,734 (1·4) 229,606 (9·0) 326,015 (12·8) 2,027,330 135,581 (6·7) 523,998 (25·8) 373,601 (18·4)
2 2,545,434 16,936 (0·7) 114,562 (4·5) 211,046 (8·3) 2,116,614 39,668 (1·9) 217,269 (10·3) 308,126 (14·6)
3 2,507,344 10,636 (0·4) 74,341 (3·0) 145,114 (5·8) 2,067,908 15,361 (0·7) 104,673 (5·1) 193,174 (9·3)
4 2,436,977 8,275 (0·3) 58,170 (2·4) 109,266 (4·5) 2,028,926 10,280 (0·5) 69,886 (3·4) 133,603 (6·6)
5 2,332,032 7,062 (0·3) 49,739 (2·1) 88,721 (3·8) 2,000,426 8,089 (0·4) 55,840 (2·8) 103,919 (5·2)
6 2,249,409 6,428 (0·3) 44,044 (2·0) 76,633 (3·4) 2,000,472 7,200 (0·4) 48,388 (2·4) 86,907 (4·3)
Fatigue
7 2,198,611 6,027 (0·3) 40,428 (1·8) 67,168 (3·1) 2,067,201 7,528 (0·4) 46,669 (2·3) 78,361 (3·8)
0 2,272,335 3,394 (0·1) 42,501 (1·9) 167,985 (7·4) 1,766,510 5,217 (0·3) 52,759 (3·0) 144,892 (8·2)
1 2,545,271 20,011 (0·8) 129,629 (5·1) 265,970 (10·4) 2,027,330 82,393 (4·1) 333,605 (16·5) 381,368 (18·8)
2 2,545,434 10,458 (0·4) 69,347 (2·7) 162,658 (6·4) 2,116,614 24,063 (1·1) 134,054 (6·3) 249,895 (11·8)
3 2,507,344 6,670 (0·3) 46,850 (1·9) 110,115 (4·4) 2,067,908 10,356 (0·5) 68,461 (3·3) 148,990 (7·2)
4 2,436,977 5,552 (0·2) 38,319 (1·6) 85,635 (3·5) 2,028,926 7,238 (0·4) 47,550 (2·3) 103,204 (5·1)
5 2,332,032 4,911 (0·2) 34,379 (1·5) 72,831 (3·1) 2,000,426 6,154 (0·3) 40,322 (2·0) 82,191 (4·1)
6 2,249,409 4,733 (0·2) 31,540 (1·4) 64,890 (2·9) 2,000,472 5,467 (0·3) 35,177 (1·8) 69,168 (3·5)
Headache
7 2,198,611 4,381 (0·2) 29,475 (1·3) 58,752 (2·7) 2,067,201 5,372 (0·3) 34,057 (1·6) 63,628 (3·1)
0 2,272,335 1,999 (0·1) 29,601 (1·3) 96,095 (4·2) 1,766,510 4,001 (0·2) 38,960 (2·2) 75,790 (4·3)
1 2,545,271 18,440 (0·7) 136,939 (5·4) 219,125 (8·6) 2,027,330 101,801 (5·0) 408,637 (20·2) 293,241 (14·5)
2 2,545,434 7,441 (0·3) 56,954 (2·2) 112,788 (4·4) 2,116,614 23,521 (1·1) 140,700 (6·6) 209,074 (9·9)
3 2,507,344 4,200 (0·2) 33,605 (1·3) 65,696 (2·6) 2,067,908 6,925 (0·3) 54,206 (2·6) 100,982 (4·9)
4 2,436,977 3,255 (0·1) 25,814 (1·1) 46,369 (1·9) 2,028,926 4,146 (0·2) 32,786 (1·6) 60,489 (3·0)
5 2,332,032 2,831 (0·1) 22,598 (1·0) 37,598 (1·6) 2,000,426 3,239 (0·2) 25,326 (1·3) 44,242 (2·2)
6 2,249,409 2,543 (0·1) 20,904 (0·9) 33,016 (1·5) 2,000,472 2,973 (0·1) 22,422 (1·1) 36,522 (1·8)
Myalgia
7 2,198,611 2,504 (0·1) 19,474 (0·9) 30,222 (1·4) 2,067,201 3,379 (0·2) 23,046 (1·1) 33,563 (1·6)
0 2,272,335 879 (0·04) 8,246 (0·4) 34,000 (1·5) 1,766,510 2,091 (0·1) 14,428 (0·8) 38,195 (2·2)
1 2,545,271 8,558 (0·3) 45,518 (1·8) 78,033 (3·1) 2,027,330 62,884 (3·1) 210,579 (10·4) 207,218 (10·2)
2 2,545,434 3,371 (0·1) 18,659 (0·7) 36,412 (1·4) 2,116,614 11,744 (0·6) 51,490 (2·4) 76,276 (3·6)
3 2,507,344 1,462 (0·1) 9,241 (0·4) 19,569 (0·8) 2,067,908 2,582 (0·1) 13,423 (0·6) 25,421 (1·2)
4 2,436,977 1,051 (0·04) 6,915 (0·3) 13,967 (0·6) 2,028,926 1,336 (0·1) 7,424 (0·4) 14,223 (0·7)
5 2,332,032 863 (0·04) 5,531 (0·2) 11,284 (0·5) 2,000,426 955 (0·05) 5,423 (0·3) 10,583 (0·5)
6 2,249,409 779 (0·03) 5,048 (0·2) 9,932 (0·4) 2,000,472 851 (0·04) 4,763 (0·2) 9,029 (0·5)
Chills
7 2,198,611 752 (0·03) 4,645 (0·2) 8,889 (0·4) 2,067,201 1,222 (0·1) 5,515 (0·3) 9,039 (0·4)
0 2,272,335 1,069 (0·05) 11,375 (0·5) 24,689 (1·1) 1,766,510 2,396 (0·1) 18,677 (1·1) 25,699 (1·5)
1 2,545,271 9,676 (0·4) 61,691 (2·4) 69,532 (2·7) 2,027,330 55,446 (2·7) 225,949 (11·2) 137,601 (6·8)
2 2,545,434 4,608 (0·2) 31,238 (1·2) 44,072 (1·7) 2,116,614 14,386 (0·7) 80,490 (3·8) 90,461 (4·3)
3 2,507,344 2,675 (0·1) 19,912 (0·8) 29,313 (1·2) 2,067,908 4,624 (0·2) 32,971 (1·6) 46,467 (2·2)
4 2,436,977 2,165 (0·1) 15,923 (0·7) 22,386 (0·9) 2,028,926 2,882 (0·1) 20,861 (1·0) 29,916 (1·5)
5 2,332,032 1,999 (0·1) 13,922 (0·6) 18,869 (0·8) 2,000,426 2,341 (0·1) 16,528 (0·8) 23,366 (1·2)
6 2,249,409 1,773 (0·1) 13,018 (0·6) 16,874 (0·8) 2,000,472 2,138 (0·1) 15,046 (0·8) 19,649 (1·0)
Joint pain
7 2,198,611 1,686 (0·1) 12,245 (0·6) 15,605 (0·7) 2,067,201 2,462 (0·1) 15,782 (0·8) 18,678 (0·9)
Data are n (%) unless otherwise stated.
*Top five reactions determined by reported frequency after second dose of both mRNA COVID-19 vaccines in v-safe, excluding fever because it
was not rated mild/moderate/severe. Symptoms are not mutually exclusive. †Mild was defined as “noticeable symptoms but they aren’t a
problem”, moderate was defined as “symptoms that limit normal activities, and severe symptoms”, and severe symptoms “make normal daily
activities difficult or impossible”.
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AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
‘Supplemental Table 6: Most common local and systemic reactions" to mRNA COVID-19 vaccine reported in
‘v-safe, by dose and severity,! 0-7 days after vaccination with mRNA-1273 vaccine
Dose 1 Dose2
Day Alln Severe Moderate Mild Alla Severe Moderate Mild
0 2112380 497102 1358264 595108082) T6567S ILIEED OSE] 535260623)
1 24APB1 4922520) 12076 IT) 12148001) 1937.9 BIIBEH —7B52MGEO —_713,164 G68)
2 2474399 1372306) 15228962) 982.7707) 203573 263513) 2683713280618 43-7)
3 2459831 477802 47.5019) 370868 05-1) 1993354 6469003) 780535) 525.158 263)
4 2,390,709 288101) 253701) 14828862) 1960829 33302 333150) 23935822)
3 2285185 20870 10B@D = TASH) 1939300 249301) 19,783.) ——1086526-7)
6 2196757 1SROH —SHEH —«50245 23) 190.754 249601) —-1802@) 6167.2),
7 2US7IO 139@D 133010 4569-1) 201937 34802 Bsa) 4M)
° 2112380 722103 746065) 170.7576) 1656723 139380 10468963) 173,749.05)
1 24D 5465923 SSIOAI) 31545403.) 1937009 240342024) 706424065) 3302457-0)
2 2474399 BS94(10) 139885) 728253 0-2) 203573 9956-0) 2925390144) 397135069)
Fatigue 3 245931 ILM@5 780362) 14793060) 1993354 190310) 126765(64) 213,889,007)
4 2390709 8430004) 5790004) ——_107.495(4-5) 1960829 1180606 8057841) 1467960)
5 228518 72203 486201) «IMG 193930 92380 6.492) 10.786)
6 2196757 648603 84900 733803) 1949.75 805104) — S2ISL@) 91.4664)
7 21S710 63003 ALORA) SITS) 201937 $7204 SQUAD) 80.798 4-0)
° 2112380 347502) 405301) 153.0867) 165673 6820 SEG) BIL EH)
1 24421 BING — 16459068 73.68701.3) 1937029 15493360) 49717157) 411266 212)
2 2474399 156140 — 91.066) 186,713 75) 203573 3979720) «198504 311816053)
3 2459431 778203 50386QD 114.6397) 1993354 1373207) 855343) 177780089)
Headache 4 2390709 581802 385670) 85140.) 1960829 3930 569740) 120.73 6D)
5 2285185 531602 439A) 7202-2) 1939300 7.2904) 4657524) 3348)
6 2196757 473202 HIST) 92ND 199.754 657603) 40021) T1284)
7 2USTIO 458502) 307054) 593968) 291937 670503) 3763409) 8333-4)
° 211238 301 @D 354A) 950884-5) 165673 775705) 5456603) IED)
1 2441 389500 —ITETG2 —«-726,7000-4) 1937009 198988003) 61OSI2G1) —292.42205-1)
2 2474399 3581 O5) SING) —1508966) 203573 3999020) 203682100) 251,594 02-4)
. 3 2459431 526402) 380861) 74647-0) 1993354 91805) 650263) AIG)
Myalgia 4 2390709 362702) 266561) -478452-0) 190829 S0N@3 368050) 6507263)
5 22518 2990) 2ISAD ANA 1939300 379602) 27454) 45,7104),
6 2196757 266701) HAD —--380600-5) 199754 35202) MOS 37.073.0.9),
7 2ASTIO 27 OD 207A 3165905) 201937 441502 250802 HEAD
o 2112380 13950) 102505) 35,178 0-7) 165673 468503) 3010-4) 45.1980)
1 24UI1 550) HH97GS) 101,682.62) 1937029 137.6850-1) 402336008) 291,400 50)
2 2474399 760103 3325803) 52.4) 203573 9390-2) 9056945) 113067)
coins 3 245981 2380) 1500) —- 2473 9) 1993354 416402 1839 3.919.
4 2390709 L374 @-) 739803) 144006 1960829 21001 9210 1632OH
5 2285185 1020-0 — 5.986(03) 116505) 1939300 154701) 658103) SOO,
6 2196757 $380.09 5.231 (02) 1016705) 19419.754 150001) 615803) 96205)
7 2ISTIOL $9100) 5.09402) 931704) 201937 23760 740504) 991505)
° 21238 L48OD —B2BEH —=—24.6660-2) 1656703 438703) 26725) 9.8680:
1 244251 2038008) 92808) 7904-3) 193709 11515269 37500494) 16383285)
2 2474399 $1003) 469609) 57,1823) 257 BSC 1538S) 116891 6-7)
Soint pat 3 2459831 35090) 2322609) —-33.0060-3) 199334 627703) 41S) 55850H
oe 4 2,390,709 240001) 1685207) 23,553 1-0) 1.960829 3,601 0-2) 245703) 4180-7)
5 22518 20CD 4ATCH «19.18 0H) 193930 28101) 189A 513203)
6 2196757 181ED 13200 —-161H) 19974 25201 1658709) LIA)
7 21710 ISHED —BIST@H — 1623008) 291937 324002) «1739009 1980000)
‘Data aren (4 ules otherwise tated
“Tepe ects etna repre Suey fer snd dv fb RNA COVIDI9 vais inh exigent ot ata
"Mid was defined 22 bt they aren't problem”, moderate was defined 32
‘hat mt norma sod vere and severe “make normal daily activities dificult
35
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36
Supplemental Table 7: Reported health impact* 0-7 days after vaccination by mRNA COVID-19 vaccine manufacturer, dose, and sex reported in v-
safe—December 14, 2020–June 14, 2021
BNT162b2 vaccine mRNA-1273 vaccine
Dose 1 (n=3,455,778) Dose 2 (n=2,920,526) Dose 1 (n=3,319,737) Dose 2 (n=2,753,894)
Sex/day
Unable to
do normal
activity
Unable to
work
Reported
medical
care
Unable to
do normal
activity
Unable to
work
Reported
medical
care
Unable to do
normal
activity
Unable to
work
Reported
medical
care
Unable to
do normal
activity
Unable to
work
Reported
medical
care
Female
Day 0 29,039 (2·1) 11,480 (0·8) 2,486 (0·2) 38,593 (3·5) 18,411 (1·7) 1,567 (0·1) 30,334 (2·4) 10,888 (0·8) 2,099 (0·2) 48,485 (4·6) 22,274 (2·1) 1,471 (0·1)
Day 1 105,123 (6·6) 41,398 (2·6) 2,810 (0·2) 324,559 (24·9) 178,887
(13·7) 3,276 (0·3) 151,710 (10·0) 60,161 (4·0) 3,370 (0·2) 522,192
(41·4) 296,178 (23·5) 4,470 (0·4)
Day 2 53,456 (3·4) 22,016 (1·4) 2,912 (0·2) 121,302 (8·9) 67,628 (5·0) 3,335 (0·2) 74,193 (4·8) 31,936 (2·1) 3,432 (0·2) 188,421
(14·2) 107,761 (8·1) 3,767 (0·3)
Day 3 35,994 (2·3) 13,399 (0·9) 3,387 (0·2) 55,917 (4·2) 24,334 (1·8) 3,695 (0·3) 40,305 (2·6) 15,496 (1·0) 3,345 (0·2) 73,844 (5·7) 32,292 (2·5) 4,052 (0·3)
Day 4 28,877 (1·9) 10,799 (0·7) 3,572 (0·2) 36,450 (2·8) 14,154 (1·1) 3,377 (0·3) 29,880 (2·0) 10,773 (0·7) 3,351 (0·2) 43,833 (3·4) 16,702 (1·3) 3,541 (0·3)
Day 5 24,765 (1·7) 9,468 (0·6) 3,548 (0·2) 29,069 (2·3) 10,747 (0·8) 3,125 (0·2) 25,056 (1·7) 9,512 (0·7) 3,467 (0·2) 32,958 (2·6) 12,195 (1·0) 3,065 (0·2)
Day 6 22,401 (1·6) 9,187 (0·7) 3,621 (0·3) 25,167 (2·0) 9,669 (0·8) 3,157 (0·2) 22,502 (1·6) 9,271 (0·7) 3,733 (0·3) 28,146 (2·2) 10,840 (0·9) 3,133 (0·2)
Day 7 20,820 (1·5) 8,801 (0·6) 3,811 (0·3) 24,955 (1·9) 10,060 (0·8) 3,419 (0·3) 21,804 (1·6) 9,242 (0·7) 4,483 (0·3) 28,538 (2·2) 12,066 (0·9) 3,272 (0·3)
Male
Day 0 8,905 (1·0) 5,711 (0·7) 569 (0·1) 11,137 (1·7) 8,208 (1·3) 380 (0·1) 8,954 (1·1) 5,339 (0·7) 479 (0·1) 13,450 (2·3) 8,955 (1·5) 337 (0·1)
Day 1 30,240 (3·2) 16,781 (1·8) 656 (0·1) 93,820 (13·3) 66,375 (9·4) 820 (0·1) 46,535 (5·3) 24,313 (2·8) 955 (0·1) 167,957
(25·6) 110,868 (16·9) 1,104 (0·2)
Day 2 13,698 (1·5) 7,846 (0·8) 767 (0·1) 29,528 (4·0) 21,766 (3·0) 768 (0·1) 21,696 (2·4) 12,307 (1·4) 836 (0·1) 47,601 (6·9) 33,333 (4·9) 785 (0·1)
Day 3 8,925 (1·0) 4,669 (0·5) 827 (0·1) 12,163 (1·7) 7,101 (1·0) 788 (0·1) 10,625 (1·2) 5,218 (0·6) 865 (0·1) 15,542 (2·3) 8,550 (1·3) 784 (0·1)
Day 4 7,267 (0·8) 3,667 (0·4) 967 (0·1) 7,978 (1·1) 4,250 (0·6) 843 (0·1) 7,670 (0·9) 3,801 (0·4) 867 (0·1) 9,428 (1·4) 4,613 (0·7) 754 (0·1)
Day 5 6,180 (0·7) 3,207 (0·4) 981 (0·1) 6,319 (0·9) 3,224 (0·5) 901 (0·1) 6,516 (0·8) 3,376 (0·4) 932 (0·1) 7,156 (1·1) 3,425 (0·5) 785 (0·1)
Day 6 5,696 (0·7) 3,019 (0·4) 1,022 (0·1) 5,790 (0·8) 2,902 (0·4) 868 (0·1) 5,829 (0·7) 3,107 (0·4) 1,035 (0·1) 6,433 (1·0) 3,146 (0·5) 793 (0·1)
Day 7 5,324 (0·7) 2,937 (0·4) 1,050 (0·1) 5,873 (0·8) 3,147 (0·4) 975 (0·1) 5,443 (0·7) 3,047 (0·4) 1,094 (0·1) 6,651 (0·9) 3,547 (0·5) 886 (0·1)
Data are n (%)†.
*Reports of health impacts are not mutually exclusive.
†Percent corresponds to number of respondents by sex and day.
PSI-HHS-000005602386
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 120 of 197 —
Deaths
500
450
350
300
250
153
100
si3
°
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
‘Supplemental Figure 1: Number of reports of death per day following vaccination, by manufacturer, to Vaccine Adverse Event Reporting System ‘Commented [BR(35]: Editorial suggestion:
(VAERS)—December 14, 2020-June 14, 2021 This wording sounds awkward and confusing. Please revise
for clarity. Consider something like “Number of reports per
day of onset” .....
Office of Science
m= BNT162b2 vaccine 2021-08-11 11:45:00
- Commented [RH(36R35]: Thanks. done
@ mRNA-1273 vaccine Rosenblum, Hannah (CDC)
2021-08-31 12:09:00
SFM NLRARARSTSERRSLERLKSZARRS
Days since last dose”
‘*x-axis reports through 161 days since last dose.
37
PSI-HHS-000005602387
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 121 of 197 —
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
‘Supplemental Figure 2: Reported health impact 0-7 days after mRNA COVID-19 vaccination by manufacturer, type of impact, and sex reported in v-
safe—December 14, 2020-June 14, 2021
4
40 40
35 235
230
3
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Dovel Bose?
Days Dayz
5 45
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o1234567 01234567 01234567 01234567
Dose Dos? Bese Dos?
Days Days
Top left: Female participants reporting health impact after receiving BNT162b2 vaccine. Top right: Female participants reporting health impact after receiving mRNA-1273
vaccine. Bottom left: Male participants reporting health impact after receiving BNT162b2 vaccine. Bottom right: Male participants reporting health impact after receiving mRNA-
1273 vaccine.
38
PSI-HHS-000005602388
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 122 of 197 —
From: "Miller, Elaine R. (CDC/DDID/NCEZID/DHQP)" < >
To: "Su, John (CDC/DDID/NCEZID/DHQP)" < >
Subject: RE: Distributing weekly data mining raw output
Date: Wed, 11 Aug 2021 20:46:08 +0000
Importance: Normal
Thanks-Can I share with Jonathan and Pedro since they are responding to inquiries?
From: Su, John (CDC/DDID/NCEZID/DHQP) < >
Sent: Wednesday, August 11, 2021 4:42 PM
To: Miller, Elaine R. (CDC/DDID/NCEZID/DHQP) < >
Subject: RE: Distributing weekly data mining raw output
Hi Elaine,
Please see enclosed, and (per FDA’s request to keep these data closer hold) don’t share. Thanks!
John
From: Miller, Elaine R. (CDC/DDID/NCEZID/DHQP) < >
Sent: Wednesday, August 11, 2021 4:33 PM
To: Menschik, David (FDA/CBER) < >; Su, John (CDC/DDID/NCEZID/DHQP) < >
Subject: RE: Distributing weekly data mining raw output
Thanks David.
John-please share this data with me.
From: Menschik, David < >
Sent: Wednesday, August 11, 2021 4:26 PM
To: Miller, Elaine R. (CDC/DDID/NCEZID/DHQP) < >
Cc: Su, John (CDC/DDID/NCEZID/DHQP) < >
Subject: Distributing weekly data mining raw output
Hi Elaine,
I saw your email about expanding the data mining raw output distribution list. Our plan is actually to limit its distribution,
largely for data security reasons.
Moving forward I’ll be forwarding this output to John Su as your group’s POC and he has discretion to share with other
team members (e.g., upon request by you/others in the group) as needed. Sorry for any inconvenience.
Best,
David
PSI-HHS-000005524064
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 123 of 197 —
From: "Su, John (CDC/DDID/NCEZID/DHQP)" < >
To: "Miller, Elaine R. (CDC/DDID/NCEZID/DHQP)" < >
Subject: RE: Distributing weekly data mining raw output
Date: Wed, 11 Aug 2021 20:41:44 +0000
Importance: Normal
Attachments: USST_20210806.xls
Hi Elaine,
Please see enclosed, and (per FDA’s request to keep these data closer hold) don’t share. Thanks!
John
From: Miller, Elaine R. (CDC/DDID/NCEZID/DHQP) < >
Sent: Wednesday, August 11, 2021 4:33 PM
To: Menschik, David (FDA/CBER) < >; Su, John (CDC/DDID/NCEZID/DHQP) < >
Subject: RE: Distributing weekly data mining raw output
Thanks David.
John-please share this data with me.
From: Menschik, David < >
Sent: Wednesday, August 11, 2021 4:26 PM
To: Miller, Elaine R. (CDC/DDID/NCEZID/DHQP) < >
Cc: Su, John (CDC/DDID/NCEZID/DHQP) < >
Subject: Distributing weekly data mining raw output
Hi Elaine,
I saw your email about expanding the data mining raw output distribution list. Our plan is actually to limit its distribution,
largely for data security reasons.
Moving forward I’ll be forwarding this output to John Su as your group’s POC and he has discretion to share with other
team members (e.g., upon request by you/others in the group) as needed. Sorry for any inconvenience.
Best,
David
PSI-HHS-000007183065
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 124 of 197 —
From: "Menschik, David" < >
To: "Zinderman, Craig E" < >
Subject: suggested edits as discussed...
Date: Fri, 07 May 2021 16:32:56 -0000
Importance: Normal
Attachments: Good_Morning_Ana.docx
…attached…
PSI-HHS-000008251530
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 125 of 197 —
Good AfternoonMorning Ana,
:
Thank you again for talking with us back in March about your work exploring new data mining
approaches and discussing your interest in CBER’s COVID-19 vaccine products. We are writing to
kindly ask that you to please hold on stop creating and sending data mining reports and analyses
using COVID-19 vaccine AE data.
In CBER OBE, we have been reviewing the various COVID-19 vaccine data mining results that you
have been forwarding. While we appreciate your interest in sharing your results, they have not
contributed to our alreadywe already have a robust process for continuous monitoring ofreviewing
incoming and aggregated VAERS (and other vaccine safety) data. I will describe a little bit below:
including:
-AESIs: CBER and CDC have established sets of AESIs (sets of PTs representing Adverse Events of
Special Interest) for key events. Incoming reports captured by these AESIs are highlighted for FDA
reviewer screening, as well as medical record follow-up and chart abstraction by CDC
reviewers. Many of the alerts that you have been sending relate to AESIs for which we are already
screening and reviewing reports, such as AMI, TTS, Thromboembolic events, and other forms of
coagulopathy. Having our staff examine your alerts creates an extra, and somewhat redundant
workstream for them, since these AESIs are already under close observation. AESIs for which we
are seeing substantial or notable reporting are further evaluated via comparisons to background
rates (using known COVID vaccine administration data tracked by CDC and provided weekly to FDA)
as well as in population-based data sources both at FDA and CDC (e.g., BEST, CMS, Vaccine Safety
Datalink (VSD)).
-Serious report screening: FDA MOs review sSerious reports coming into VAERS daily until meeting
specified milestone and then ; for the first couple months with the mRNA vaccines, and still
currently for JnJ, FDA MOs review each serious report as it is processed into VAERS. For the older
mRNA vaccines, MOs now conduct weekly review of aggregated PT counts by seriousness, AESI, Lot
number, most frequent PTs, weekly changes in PT rankings, and other metrics.
-Pre-screening: for a couple of notable issues, the VAERS program contractor flags reports when
they hit the door: these pre-screened events will have expedited gathering of medical records and
CDC review and abstraction. TTS and anaphylaxis both have fallen into this category.
Of note, data mining alerts, which are designed to generate hypotheses of possible safety issues,
are no longer particularly useful for our pharmacovigilance purposes when a signal has already
been identified, such as for TTS, or when an issue (e.g., an AESI such as AMI) is being worked up in a
more robust (e.g., active surveillance) system.. Some alerts that you have sent, like for AMI, have
already temporarily signaled in population-based surveillance, which has already triggered a more
thorough review of VAERS data.
Also as you knowFurther, we have a standard process for data mining screening in place for VAERS
data; this screening was in place at the start of, and throughout, the COVID vaccine campaign; the
frequency/nature of the calculations, stratifications and other parameters, are known and
understood by us and our stakeholders. We understand that exploring new approaches and
varying the stratifications or other parameters might improve the methodology and is of interest to
you. However, from our perspective, the approach employed during a period of intense, high
profile surveillance should be standard, and predictable, and road-tested. Results from Aadjusting
parameters thato raise or lower sensitivity of the alerts as the vaccination campaign is underway
could lead to some artificial creation of alerts and an apparent, but not real, sudden change in
safety results. confusion and have unintended consequences (e.g., regarding vaccine confidence).
PSI-HHS-000008251912
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 126 of 197 —
So, while we appreciate your work and interest at CDER on the COVID vaccine VAERS data, for all of
the above reasons, in the above context, we have found that examining the analyses you have been
sending has largely reflected events otherwise under evaluationno indication for action based on
your findings, which have been consuming a lot of resources at a time when resources are
stretched across a preexisting robust pharmacovigilance infrastructure. We haven’t seen a
proportionate increase in efficiency or yield, given the robust screening and scrutiny of VAERS data
already in place as described above. We’d hate for you to be wasting your time and efforts, so we
thought we should suggest that it might be a better use of resources for you to refocus your data
mining efforts on other product types. Perhaps there are CDER products and drug related data in
your Center that could benefit more from your continued data mining explorations and analyses.
Thanks much for your time and attentionunderstanding, and; sorry for the long email.
Kind regards,Thanks,
Craig Zinderman, MD, MPH
Associate Director for Medical Policy
Office of Biostatistics and Epidemiology
FDA/Center for Biologics Evaluation and Research
PSI-HHS-000008251913
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 127 of 197 —
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
From: "Menschik, David"
To: "Baer, Bethany" >, "Zinderman, Craig E"
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when
the product of interest is in almost all of the reports
Date: Thu, 15 Apr 2021 15:06:11 -0000
Importance: Normal
Inline-Images: image001.png
Sorry— didn’t see that — will reschedule
Sent: Thursday, April 15, 2021 11:05 AM
To: Menschik, David <i>: Zinderman, Craig ¢ ir
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
lam on leave tomorrow so can’t attend. | am free most of Monday and Tuesday except for a few meetings.
Bethany
From: Menschik, David ti‘ ‘ir
Sent: Thursday, April 15, 2021 10:41 AM
To: Baer, Bethany <i: Zinderman, Craig <i
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
Sending invite for tomorrow at noon
Sent: Thursday, April 15, 2021 10:07 AM
To: Menschik, David <i>: Zinderman, Craig ¢ i
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
Sounds good. Happy to meet and discuss anytime open on my calendar.
Bethany
From: Menschik, David -ti—(‘“‘i‘al
Sent: Thursday, April 15, 2021 9:31 AM
To: Baer, Sethany <i: Zinderman, Craig <i
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
Before we potentially reach out to Ana, we should meet internally— many considerations not suited to email...
Sent: Thursday, April 15, 2021 9:27 AM
To: Baer, Bethany >; Zinderman, Craig E <n” >; Venschik, David
>
PSI-HHS-000008251979
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 128 of 197 —
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
I’ll forward you Ana’s email with the attachment. The best person to ask would be Ana as she has close ties with Bill
Dumouchel.
Thank you!
Manette
From: Baer, Bethany < gov>
Sent: Thursday, April 15, 2021 9:00 AM
To: Zinderman, Craig E < >; Menschik, David < >
Cc: Niu, Manette < >
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
Thanks for forwarding this on. I agree that we should consider different approaches as the underlying database is
changing significantly due to the high volume of COVID vaccine reports. I think we should welcome any expert input. The
spreadsheet that Bill mentioned in the first email is not attached so I can’t look at it, but David and I have been discussing
and are concerned about the effect of so many COVID reports on the standard system we use. Is there a way that Bill can
be more involved in our data mining process and interpretation during this unprecedented reporting time?
Thanks,
Bethany
From: Zinderman, Craig E < >
Sent: Wednesday, April 14, 2021 2:02 PM
To: Menschik, David < >; Baer, Bethany < >
Cc: Niu, Manette < >
Subject: FW: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
David, Bethany:
Might be worth considering the below? I don’t pretend to understand it, but sounds like they are suggesting an analysis
not stratified by year. Thoughts?
Thanks,
Craig
From: Niu, Manette < >
Sent: Wednesday, April 14, 2021 6:24 AM
To: Zinderman, Craig E < >
Subject: FW: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
fyi
From: Szarfman, Ana < >
Sent: Tuesday, April 13, 2021 9:17 PM
To: Niu, Manette < >
Cc: Stockbridge, Norman L < >
Subject: RE: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
PSI-HHS-000008251980
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 129 of 197 —
Thanks Manette.
Exactly. As DuMouchel pinpointed, there is a need to extend the stratification brackets by the fact that 99% of the results
for FY2021 are for COVID-19 vaccines this indeed affects the results.
From: Niu, Manette < >
Sent: Monday, April 12, 2021 7:01 AM
To: Szarfman, Ana < >
Subject: FW: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest
is in almost all of the reports
Ana,
Does this effect the data mining results we are receiving in 2021? As you know, there is a backlog in VAERS reports with
the contractor due to the high volume of reports we are receiving for the COVID-19 vaccines and the prioritization of
those vaccine reports.
Thank you!
Manette
From: Szarfman, Ana < >
Sent: Saturday, April 10, 2021 1:22 PM
To: Niu, Manette < >
Cc: Vega, Amarilys < >; Stockbridge, Norman L < >; Quinn,
John < >; bill.dumouchel < >; Rave Harpaz
< >; Pease-Fye, Meg < >; Weichold, Frank
< >; Callahan, Lawrence < >; Paredes, Antonio
< >; Temple, Robert < >; Blum, Michael
< >; Dal Pan, Gerald < >; Zander, Judith
< >; Munoz, Monica < >; Diak, Ida-Lina <
>
Subject: Important analysis by DuMouchel -> Peculiarities of disproportionality statistics when the product of interest is in
almost all of the reports
Hello all,
Please refer to the message from Bill DuMouchel that I am forwarding and to his attached spreadsheet.
Notice how Bill discovered the need to eliminate the stratification by year when the reports for the COVID-19 vaccine in
VAERS are 99% of all reports for a year (2021).
I think that we need to invite him to talk with us about the effect of adjustment factors, given the data, so we can all learn
from his knowledge.
Warmest regards to all,
--Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical Informatics (2017), and
Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
Celebrating nearly a quarter of a century of successful implementation of safety data mining, interactive patient profiles,
and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food and Drug Administration
PSI-HHS-000008251981
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 130 of 197 —
From: Bill DuMouchel < >
Sent: Saturday, April 10, 2021 2:25 AM
To: Rave Harpaz < >; Steve Bright < >; Rob Van Manen
< >
Cc: Szarfman, Ana < >; Mohammad Al-Ansari < >; Robert
Weber < >; Bruce Palsulich < >
Subject: [EXTERNAL] Peculiarities of disproportionality statistics when the product of interest is in almost all of the reports
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
The attached spreadsheet shows some COVID19 results for the three-year period 2019-2021
2019 has no COVID19 reports
2020 has a few
2021 consists of almost all (33929/34256 > 99%) COVID99 reports
Look at the values of A, B, C, D ... A+C is much greater than B+D in 2021.
The years 2020 and 2021 are shown as separate analyses. Note that RR as well as the Bayesian estimates are
almost equal to 1.
They stay almost equal to one if the run is stratified by year, because the 2021 results dominate.
The next two sets of results show the full 3-year estimates with and without including year as one of the
stratification covariates.
Only if you mix in more non-covid reports within each stratum can you get enough diversity to allow larger
disproportionalities.
-Bill
PSI-HHS-000008251982
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 131 of 197 —
From: "Menschik, David" < >
To: "Zinderman, Craig E" < >
Bcc: "Menschik, David" < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Date: Wed, 08 Sep 2021 10:49:16 -0000
Importance: Normal
Attachments: Draft_proposed_respponse_on_age_stratification.docx
Inline-Images: image001.png; image002.png
Hi Craig, I made some edits to draft proposed response (per attached) in advance of discussing…
From: Menschik, David < >
Sent: Saturday, September 04, 2021 7:18 AM
To: Zinderman, Craig E < >
Subject: FW: CBER VAERS Signal Management Liaisons/Contacts
FYI and before potential response, let’s discuss any thoughts you or I may have by phone when we’re back next week.
From: Szarfman, Ana < >
Sent: Friday, September 03, 2021 5:50 PM
To: Hendrix, Brian * >; Sydnor, James * < >; Menschik, David
< >
Cc: Lebow, William * < >; Baer, Bethany < >; Siegel, Jeffrey
< >; Stockbridge, Norman L < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Brian,
Thanks so much for the wonderful job you are all doing.
Hi David,
I noticed that you are Board Certified in Clinical Informatics. Congratulations!
Regarding the question I posted to Brian:
Why I am concerned about stratifying the VAERS data by year?
Most of the VAERS reports for 2021 are for the COVID-19 vaccines.
By stratifying by year you are only using one year of data.
For a sound data mining analysis, more than half of the reports need to be for other vaccines.
Usually the control group would have 5 or 10 as many cases as the products of interest.
If you only want to compare the 3 different COVID-19 vaccines with each other, this would OK, but the 3 vaccines
could be doing the same bad thing, and you would not know it.
By stratifying by year, the background would be composed by the covid-19 vaccines.
Astra Zeneca in their demo at the Accelerator meeting, presented data not stratified by year, for this same
reason.
Using the RGPS data mining algorithm vs MGPS
PSI-HHS-000008252951
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 132 of 197 —
RGPS is much, much better at unmasking signals than MGPS.
It automatically identifies and corrects for confounders.
This is an important function to have, given the pandemic situation.
I hope we continue helping each other.
Let me know if you need further information.
--Ana
Ana Szarfman, MD, PhD, FAMIA,
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 3:24 PM
To: Szarfman, Ana < >; Sydnor, James * < >
Cc: Menschik, David < >; Lebow, William * < >; Baer, Bethany
< >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Ana,
Thank you for bringing this up.
Currently all of the VAERS DM runs are being stratified by year.
Given the large proportion of covid-19 events, we will need to look at this going forward.
I’ve copied David and Bethany here to make them aware as well.
-Brian
From: Szarfman, Ana < >
Sent: Friday, September 3, 2021 2:16 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Therefore the background will only be for covid-19 vaccines, instead of for other vaccines. Therefore, masking covid-19
vaccine signals that are common with these vaccines, but not common across other types of vaccines.
From: Szarfman, Ana
Sent: Friday, September 3, 2021 2:07 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
For VAERS. Over 95% of the reports in 2021 are for COVID-19 vaccines.
PSI-HHS-000008252952
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 133 of 197 —
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 2:06 PM
To: Szarfman, Ana < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
For VAERS or across Signal in general?
From: Szarfman, Ana < >
Sent: Friday, September 3, 2021 2:06 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Thanks Brian and Casey,
Are any of the DM runs being generated NOT BEING stratified by year?
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 2:02 PM
To: Sydnor, James * < >
Cc: Szarfman, Ana < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Ana,
Can you please let me know which runs you have concerns about? I can provide details of the run structures as needed.
Thank you,
Brian
From: Sydnor, James * < >
Sent: Friday, September 3, 2021 1:58 PM
To: Hendrix, Brian * < >
Cc: Szarfman, Ana < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Brian,
Ana has a concern regarding the new CBER VAERS Data Mining and Signal Management runs regarding the possibility that
they may be stratifying by Year. I know that there were a number of discussions about the criterial for the runs, so I’m
fairly certain that we do not stratify by Year because of the issues with the background that would occur for the most
recent months. Please confirm briefly if you can so that Ana can approach David and Bethany with a little bit of
background. Thank you!
Best regards,
Casey Sydnor (contractor)
Commonwealth Informatics, Inc.
Empirica Signal Support Team
PSI-HHS-000008252953
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 134 of 197 —
From: Sydnor, James *
Sent: Friday, September 3, 2021 1:54 PM
To: Szarfman, Ana < >
Cc: Hendrix, Brian * < >
Subject: CBER VAERS Signal Management Liaisons/Contacts
Ana,
As we discussed on the phone, you will need to reach out to David Menschik and Bethany Baer (contact info below) in
order to discuss your interest in the new CBER VAERS Signal Management runs. Please let Brian and me know if/how we
can help after you have discussed with David and Bethany. You can copy us on the correspondence with them if you like,
so that we can remain in the loop to know how the conversation is resolved. Best of luck and we wish you a wonderful
long weekend!
David Menschik, MD, MPH
Associate Director for Surveillance Informatics
Division of Epidemiology/Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research/FDA
Bethany Baer
Physician
Division of Epidemiology/Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research/FDA
Best regards,
Casey Sydnor (contractor)
Commonwealth Informatics, Inc.
Empirica Signal Support Team
Office Of Translational Sciences
FDA/CDER/OTS
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Draft proposed response:
Hi Ana,
I certainly understand where you are coming from.
While we must limit access to VAERS Empirica data mining data to those within the CBER/OBE/DE
chain of command for reasons including CBER contractual/budgetary policies and data security, I
can in general speak to the understandable concern that you raise regarding stratifying by year.
We have previously thought about and discussed this issue, recognizing that the vast-majority of
reports received in VAERS this year have involved COVID-19 vaccines which could drive PT-vaccine
disproportionately scores towards the null by contributing substantially to the comparator group,
particularly if there is a class-effect (e.g., if all COVID vaccines are associated with the same adverse
event). While you have laid out reasonable arguments (which had generally occurred to us) why
stratifying VAERS data by year raises new limitations in interpreting data output using existing
methods, there are sound reasons for retaining adjustment by year.
From an epidemiology standpoint, exposures and health outcomes (not to mention public
perceptions, behaviors, practices, etc. whether stimulated or not) can vary dramatically from one
year to the next (independent of vaccinations) and such disparities by year can increase with
increasing number of years. For example, during the ‘COVID era,’ circulating SARS-CoV-2 disease
can drive a substantial increase in reported specific AEs, independently of AEs that may be
associated with vaccinations; these AEs would most likely be over-represented in individual COVID
vaccine-AE disproportionality scores if the comparison group were expanded to include reports
from increasing time periods prior to the ‘COVID-era.’
On a related note, MedDRA terms are continuously being updated and can regularly have
substantial updates introducing new AE terms not available when reports were coded during prior
time periods. For instance, this past week (under version 24.1 release), a new preferred term (PT),
“multisystem inflammatory syndrome” was added to MedDRA. Without controlling for time (e.g.,
year) of vaccination, there would likely be inflated disproportionality for newer MedDRA AE terms
in association with COVID vaccines since an expanded comparison group would include
substantially more VAERS reports that have no chance of having such newer MedDRA terms due to
being coded prior to the availability of such a term.
We will plan to discuss internally within CBER/OBE/DE and with Commonwealth options and
associated feasibilities, impacts, etc. for potential approaches to addressing the age-stratification
issue. Any further discussion on VAERS data mining methods/findings outside my chain of
command (for reasons including data security) will have to be offline and in general terms, as well
as without reference to any specific VAERS vaccine-PT pair outputs.
Thank you for your understanding,
David
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From: "Menschik, David" < >
To: "Zinderman, Craig E" < >
Bcc: "Menschik, David" < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Date: Mon, 06 Sep 2021 13:03:27 -0000
Importance: Normal
Attachments: Draft_proposed_respponse_on_age_stratification.docx
Inline-Images: image001.png; image002.png
Thanks and agree. I’ve given this a lot of thought. Please see my attached draft proposed response to Ana. Would
welcome any suggested edits and advice on who to include on ‘to’ and ‘cc’ lines though would like to discuss first by
phone with you (feel free to call my cell) before proceeding farther...
Thanks,
David
From: Zinderman, Craig E < >
Sent: Sunday, September 05, 2021 3:16 PM
To: Menschik, David < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Thanks David. Happy to discuss options; I would lean towards having some scientific rationale/data to support an
approach.
Thanks,
Craig.
From: Menschik, David < >
Sent: Saturday, September 04, 2021 7:18 AM
To: Zinderman, Craig E < >
Subject: FW: CBER VAERS Signal Management Liaisons/Contacts
FYI and before potential response, let’s discuss any thoughts you or I may have by phone when we’re back next week.
From: Szarfman, Ana < >
Sent: Friday, September 03, 2021 5:50 PM
To: Hendrix, Brian * < >; Sydnor, James * < >; Menschik, David
< >
Cc: Lebow, William * < >; Baer, Bethany < >; Siegel, Jeffrey
< >; Stockbridge, Norman L < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Brian,
Thanks so much for the wonderful job you are all doing.
Hi David,
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I noticed that you are Board Certified in Clinical Informatics. Congratulations!
Regarding the question I posted to Brian:
Why I am concerned about stratifying the VAERS data by year?
Most of the VAERS reports for 2021 are for the COVID-19 vaccines.
By stratifying by year you are only using one year of data.
For a sound data mining analysis, more than half of the reports need to be for other vaccines.
Usually the control group would have 5 or 10 as many cases as the products of interest.
If you only want to compare the 3 different COVID-19 vaccines with each other, this would OK, but the 3 vaccines
could be doing the same bad thing, and you would not know it.
By stratifying by year, the background would be composed by the covid-19 vaccines.
Astra Zeneca in their demo at the Accelerator meeting, presented data not stratified by year, for this same
reason.
Using the RGPS data mining algorithm vs MGPS
RGPS is much, much better at unmasking signals than MGPS.
It automatically identifies and corrects for confounders.
This is an important function to have, given the pandemic situation.
I hope we continue helping each other.
Let me know if you need further information.
--Ana
Ana Szarfman, MD, PhD, FAMIA,
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 3:24 PM
To: Szarfman, Ana < >; Sydnor, James * < >
Cc: Menschik, David < >; Lebow, William * < >; Baer, Bethany
< >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Ana,
Thank you for bringing this up.
Currently all of the VAERS DM runs are being stratified by year.
Given the large proportion of covid-19 events, we will need to look at this going forward.
I’ve copied David and Bethany here to make them aware as well.
PSI-HHS-000008253099
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— Page 138 of 197 —
-Brian
From: Szarfman, Ana < >
Sent: Friday, September 3, 2021 2:16 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Therefore the background will only be for covid-19 vaccines, instead of for other vaccines. Therefore, masking covid-19
vaccine signals that are common with these vaccines, but not common across other types of vaccines.
From: Szarfman, Ana
Sent: Friday, September 3, 2021 2:07 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
For VAERS. Over 95% of the reports in 2021 are for COVID-19 vaccines.
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 2:06 PM
To: Szarfman, Ana < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
For VAERS or across Signal in general?
From: Szarfman, Ana < >
Sent: Friday, September 3, 2021 2:06 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Thanks Brian and Casey,
Are any of the DM runs being generated NOT BEING stratified by year?
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 2:02 PM
To: Sydnor, James * < >
Cc: Szarfman, Ana < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Ana,
Can you please let me know which runs you have concerns about? I can provide details of the run structures as needed.
Thank you,
Brian
From: Sydnor, James * < >
Sent: Friday, September 3, 2021 1:58 PM
To: Hendrix, Brian * < >
Cc: Szarfman, Ana < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
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Brian,
Ana has a concern regarding the new CBER VAERS Data Mining and Signal Management runs regarding the possibility that
they may be stratifying by Year. I know that there were a number of discussions about the criterial for the runs, so I’m
fairly certain that we do not stratify by Year because of the issues with the background that would occur for the most
recent months. Please confirm briefly if you can so that Ana can approach David and Bethany with a little bit of
background. Thank you!
Best regards,
Casey Sydnor (contractor)
Commonwealth Informatics, Inc.
Empirica Signal Support Team
From: Sydnor, James *
Sent: Friday, September 3, 2021 1:54 PM
To: Szarfman, Ana < >
Cc: Hendrix, Brian * < >
Subject: CBER VAERS Signal Management Liaisons/Contacts
Ana,
As we discussed on the phone, you will need to reach out to David Menschik and Bethany Baer (contact info below) in
order to discuss your interest in the new CBER VAERS Signal Management runs. Please let Brian and me know if/how we
can help after you have discussed with David and Bethany. You can copy us on the correspondence with them if you like,
so that we can remain in the loop to know how the conversation is resolved. Best of luck and we wish you a wonderful
long weekend!
David Menschik, MD, MPH
Associate Director for Surveillance Informatics
Division of Epidemiology/Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research/FDA
Bethany Baer
Physician
Division of Epidemiology/Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research/FDA
Best regards,
Casey Sydnor (contractor)
PSI-HHS-000008253101
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
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Commonwealth Informatics, Inc.
Empirica Signal Support Team
Office Of Translational Sciences
FDA/CDER/OTS
PSI-HHS-000008253102
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
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Draft proposed response:
Hi Ana,
I certainly understand where you are coming from.
While we must limit access to VAERS Empirica data mining data to those within the CBER/OBE/DE
chain of command for reasons including contractual financial as well as data security reasons, I can
in general speak to the concern that you raise regarding stratifying by year.
We have previously thought about and discussed this issue, recognizing that the vast-majority of
reports in VAERS this year have involved COVID-19 vaccines which could drive PT-vaccine
disproportionately scores towards the null by contributing substantially to the comparator group,
particularly if there is a class-effect (e.g., if all COVID vaccines are associated with the same adverse
event). While you have laid out reasonable arguments (which had generally occurred to us) why
stratifying VAERS data by year raises new limitations in interpreting data output using existing
methods, there are sound reasons for retaining adjustment by year including:
From an epidemiology standpoint, exposures and health outcomes (not to mention public
perceptions, behaviors, practices, etc. whether stimulated or not) can vary dramatically from one
year to the next (independent of vaccinations) and such disparities by year can increase with
increasing number of years. For example, during the ‘COVID era,’ circulating SARS-CoV-2 disease
can drive a substantial increase in reported specific AEs, independently of AEs that may be
associated with vaccinations; these AEs would most likely be over-represented in individual COVID
vaccine-AE disproportionality scores if the comparison group were expanded to include reports
from increasing time periods prior to the ‘COVID-era.’
On a related note, MedDRA terms are continuously being updated and can regularly have
substantial updates introducing new AE terms not available when reports were coded during prior
time periods. For instance, this past week (under version 24.1 release), a new preferred term (PT),
“multisystem inflammatory syndrome” was added to MedDRA. Without controlling for time (e.g.,
year) of vaccination, there would likely be inflated disproportionality for newer MedDRA AE terms
in association with COVID vaccines since an expanded comparison group would include
substantially more VAERS reports that have no chance of having such newer MedDRA terms due to
being coded prior to the availability of a given term.
We will plan to discuss internally within DE and with Commonwealth options and associated
feasibilities, impacts, etc. for potential approaches to addressing the age-stratification issue (e.g.,
exploring adjustment stratifications of more than one year). Any further discussion on VAERS data
mining methods outside my chain of command (for reasons including data security) will have to be
offline and in general terms, without reference to any specific VAERS vaccine-PT pairs.
Thank you for your understanding,
David
PSI-HHS-000008253959
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From: "Menschik, David" < >
To: "Baer, Bethany" < >
Subject: RE: [External] : CORRECTION: Following up on today's discussion
Date: Thu, 26 Sep 2024 17:55:58 -0000
Importance: Normal
Inline-Images: image001.jpg
Thanks for sharing – I also explored a bit and found that in general the ER05 appears way more sensitive in that its scores
are generally higher than corresponding EB05 scores when sampling different PTs – this resulted in a lot more ‘statistical
signals’ using their SDR threshold in the sandbox. We can discuss more offline though agree for now our focus should be
on preserving current functions, features, outputs, etc.
Wishing you fantastic travels!
David
From: Baer, Bethany < >
Sent: Thursday, September 26, 2024 1:46 PM
To: Menschik, David < >
Subject: RE: [External] : CORRECTION: Following up on today's discussion
Hi David,
I spent some time yesterday and today exploring the ER05. I have previously read the Harpaz/Szarfman publication and
have now read the DuMouchel white paper. I feel I understand the concept and big picture, but then I was completely out
of my league on p. 6 of the white paper when the detailed methodology part started. I added the ER05 column to my
signals view and saw that for Gardasil the ER05 is significantly higher (numbers in teens-twenties) than the EB05 for the
same PTs and Ns (EB05s were 3-5). Then for 1 PT (psychogenic pseudosyncope), the ER05 and EB05 were the exact same.
The Pfizer covid bivalent had numbers that were overall closer to each other for the ER05 and EB05 of many PTs, with the
ER05 frequently being around 0.5-1 higher than the EB05.
So, I understand the theory behind masking and trying to adjust for it, but I feel that comprehending the details of the
approach and, importantly, which approach is “better,” is beyond my training and experience. I think someone with more
data mining expertise would have to be involved in that decision. I don’t think I have more to add regarding the ER05. I
also don’t have any specific questions for the Oracle team for Friday. From my question last week, it didn’t sound like that
is the group to have an in-depth discussion regarding ER05. I really appreciate the documents they forwarded to us.
Let me know if you have any questions regarding this. I wanted to get you my thoughts before I head out on leave next
week.
Thanks,
Bethany
From: Menschik, David < >
Sent: Tuesday, September 24, 2024 2:32 PM
To: Baer, Bethany < >; Panchanathan, Sarada < >; Thompson,
Deborah < >
Cc: Zinderman, Craig < >
Subject: RE: [External] : CORRECTION: Following up on today's discussion
Thanks all for the prompt feedback. I checked WONDER and found comparable counts (e.g., n=49 for ‘drug ineffective and
Pfizer bivalent) to what we’ve observed in new Empirica so New Empirica’s not picking up the extra cases is not its fault
and it does indicate to me that the difference is related to differences between our internal data set and the public data
set. Based on this, I’m ok to move on beyond this discrepancy issue. Agree with not meeting and also please advise if you
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have any items to discuss on Friday. I don’t have any new items to discuss with Oracle and if none of you do by Thursday
afternoon, I can propose to cancel the meeting.
Thanks,
David
From: Baer, Bethany < >
Sent: Tuesday, September 24, 2024 1:07 PM
To: Panchanathan, Sarada < >; Thompson, Deborah
< >; Menschik, David < >
Subject: RE: [External] : CORRECTION: Following up on today's discussion
I don’t need to meet either. My thought about what they said about the brain fog cases was just the question of would
those different procedures be aligned if we went with New Empirica and they had our in-house data? I don’t know the
procedure for when a new PT is added to Meddra and how old reports are handled – but I understand if they say that is
the difference between the processes. The issue would then only show up for relatively new PTs with a lot of reports but
also some older reports in the system not previously coded– like brain fog.
-Bethany
From: Panchanathan, Sarada < >
Sent: Tuesday, September 24, 2024 12:12 PM
To: Thompson, Deborah < >; Menschik, David < >; Baer,
Bethany < >
Subject: RE: [External] : CORRECTION: Following up on today's discussion
I don’t need to meet, but also happy to meet if needed.
Warm regards,
Soumya
From: Thompson, Deborah < >
Sent: Tuesday, September 24, 2024 11:47 AM
To: Menschik, David < >; Baer, Bethany < >; Panchanathan, Sarada
< >
Subject: RE: [External] : CORRECTION: Following up on today's discussion
Thanks, David. Agree. I don’t think we need a huddle before meeting with Oracle on Friday, but am happy to meet if
preferred by others.
Thanks,
Deb
From: Menschik, David < >
Sent: Tuesday, September 24, 2024 11:19 AM
To: Thompson, Deborah < >; Baer, Bethany < >; Panchanathan,
Sarada < >
Subject: FW: [External] : CORRECTION: Following up on today's discussion
FYI - don’t think it makes sense to share thoughts with Oracle over email though please advise if you have any thoughts
and would like to huddle before our meeting with Oracle on Friday…
From: Menschik, David
Sent: Tuesday, September 24, 2024 11:17 AM
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AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
Ce: Alimchandani, Meghna >
Subject: RE: [External] : CORRECTION: Following up on today's discussion
Thank you Robert for sharing these helpful observations and thoughts. We'll also plan to take a closer look and looking
forward to regrouping on Friday.
Best regards,
David
Sent: Monday, September 23, 2024 8:57 AM
To: Menschik, David >; Philip Sheridan <j>
Ce: Alimchandani, Meghna >
Subject: Re: [External] : CORRECTION: Following up on today's discussion
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
Thank you, David.
After a first pass, | noticed the following points — sharing observations early in case you want to add further
details at this stage. We will keep investigating this more thoroughly.
#1: The list of cases shared shows up as “COVID19 (PFIZER-BIONTECH)’, i.e. the monovalent product, in our
database. When looking at a few examples, | noticed that the narrative was indicating uncertainty about the
exact product/batch no — have these cases potentially ben re-coded in your inhouse database due some other
information that might not be available in the public datasets? | also found cases clearly coded as bivalent
Pfizer missing in the list you provided.
With the numbers currently coded as bivalent in our database, the disproportionality scores for bivalent Pfizer
are low due to the large number of drug ineffective cases attributed to other COVID vaccines, in particular
monovalent Pfizer.
#2: Here, the number of Brain fog cases (25) appears to be limited to those reported after the PT being added
to MedDRA, while your list also has older cases mentioning Brain fog in the narrative. My suspicion is that the
discrepancy is due to data preparation differences between your inhouse database and the public datasets we
are using for the VAERS data loaded into the sandbox. We are looking into this further.
Best regards,
Robert
From: Menschik, David Sree ell
Date: Friday, 20. September at 19:
To: Philip Sheridan > Robert Weber <j>
Ce: Alimchandani, Meghna >
Subject: [External] : CORR : Following up on today's discussion
Apologies: | had an error in my earlier email, the sandbox sample size in example two was 25.
Sorry for my mistake,
David
From: Menschik, David
Sent: Friday, September 20, 2024 1:21 PM
To: Philip Sheridan <i>; Robert Weber _i—— rs -
PSI-HHS-000008253426
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Cc: Alimchandani, Meghna < >
Subject: Following up on today's discussion
Hi Robert and Phil,
Thanks for a helpful workshop session earlier today. As discussed, attached please find VAERS IDs with received date
through 1/31/2024 for the two examples we discussed with corresponding sandbox output as follows:
1. Pfizer Bivalent and PT ‘Drug ineffective’ using “VAERS 202401: US Only” run (N=49, EB05=0.060)
Note: expected much higher EB05 (>2)
2. Gardasil and PT ‘Brain fog” using “VAERS 202401: All” run (N=211 25, EB05=7.78)
Note: expected much lower EB05 (close to 2)
As you can observe, our counts are substantially higher for both and wondering why so many VAERS IDs are missing in the
sandbox.
Thanks and have a great weekend,
David
David Menschik, MD, MPH
Associate Director for Surveillance Informatics
Division of Pharmacovigilance/Office of Biostatistics and Pharmacovigilance
Center for Biologics Evaluation and Research/FDA
THIS MESSAGE, INCLUDING ANY ATTACHMENTS, IS INTENDED ONLY FOR THE USE OF THE PARTY TO WHOM IT IS ADDRESSED AND MAY
CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND PROTECTED FROM DISCLOSURE UNDER LAW If you are not the addressee, or a
person authorized to deliver the document to the addressee, you are hereby notified that any review, disclosure, dissemination, copying, or other action based on the
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From: "Menschik, David" < >
To: "Zinderman, Craig E" < >
Subject: RE: suggested edits as discussed...
Date: Fri, 07 May 2021 18:58:47 -0000
Importance: Normal
thanks
From: Zinderman, Craig E < >
Sent: Friday, May 07, 2021 2:58 PM
To: Menschik, David < >; Nair, Narayan < >
Subject: RE: suggested edits as discussed...
Yup, agree. I will send a new version to NN.
Thanks,
Craig
From: Menschik, David < >
Sent: Friday, May 07, 2021 2:56 PM
To: Zinderman, Craig E < >
Subject: RE: suggested edits as discussed...
Yes I like that, followed by “Thanks much for your understanding…”
From: Zinderman, Craig E < >
Sent: Friday, May 07, 2021 2:54 PM
To: Menschik, David < >
Subject: RE: suggested edits as discussed...
Got it; understood. Maybe we should just restate the ask at the end of the last paragraph:
“So, we are asking that you please hold on creating and sending data mining results for COVID-19 vaccine AE data.“
Thanks,
Craig
From: Menschik, David < >
Sent: Friday, May 07, 2021 2:51 PM
To: Zinderman, Craig E < >
Subject: RE: suggested edits as discussed...
Thanks – I removed the language in the last paragraph since I didn’t want it to be misconstrued as patronizing (obviously
far from your intention…)
From: Zinderman, Craig E < >
Sent: Friday, May 07, 2021 2:49 PM
PSI-HHS-000008253450
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 147 of 197 —
To: Menschik, David < >; Nair, Narayan < >
Subject: RE: suggested edits as discussed...
Narayan:
I drafted, and David edited, the attached message to Ana as discussed. Please feel free to edits as you see fit. It’s pretty
long so feel to shorten if you can see any opportunity for that.
I put it in Word for ease of tracked changes.
Thanks,
Craig
From: Menschik, David < >
Sent: Friday, May 07, 2021 12:33 PM
To: Zinderman, Craig E < >
Subject: suggested edits as discussed...
…attached…
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From: "Menschik, David" < >
To: "Baer, Bethany"
Subject: RE: Signal Management
Date: Fri, 08 Jan 2021 16:56:52 -0000
Importance: Normal
Attachments: VAERS_data_mining_20210106.pptx
Inline-Images: image001.png
Thanks! I revised the second slide accordingly – could you please look at this slide and let me know if it looks ok? Also wanted to confirm if I have
the correct reference in the footnote.
Thanks,
David
From: Baer, Bethany < >
Sent: Friday, January 08, 2021 11:25 AM
To: Menschik, David < >
Subject: RE: Signal Management
I think the slides look good. I looked back at a few classic data mining references (some Szarfman and DuMouchel papers) and saw that the most
common EBGM definition seems to be “Empiric Bayes Geometric Mean.” Sometimes it isn’t all capitalized and sometimes “empirical” or
“Bayesian” is used, but the “Empiric” as the first word form seems most common. I don’t think any of them are wrong, and I admit that I have
been inconsistent about their use myself.
My only other comment is that if the audience is more sophisticated or wants more statistical info, the presenter should know the term Multi-
item Gamma Poisson Shrinker (MGPS) – the algorithm that our data mining uses. As Szarfman’s 2004 Pharmacotherapy paper explains: “The
MGPS systematically identifies and ‘shrinks’ the very common and volatile observed:expected ratios with the smaller number of events and
expectations. This process guards against generating multiple false-positive signals due to multiple independent comparisons.” Referring to the
MGPS provides that next level of statistical details that folks like Paige at the CDC have asked about in the past.
Thanks,
Bethany
From: Menschik, David < >
Sent: Friday, January 8, 2021 10:43 AM
To: Baer, Bethany < >
Subject: RE: Signal Management
Ahhh…thanks!
On different note, any feedback or edits for the 3 slides I drafted based on your slides appreciated… (will likely be sharing with CDC next week…)
Thanks,
David
From: Baer, Bethany < >
Sent: Friday, January 08, 2021 10:41 AM
To: Menschik, David < >
Subject: RE: Signal Management
It’s a foreign brand name not licensed in the US. We see different ones like that every months or two.
From: Menschik, David < >
Sent: Friday, January 8, 2021 10:34 AM
To: Baer, Bethany < >
Subject: RE: Signal Management
I’m not familiar with Fluenz tetra – is that a new product and should it be added too? (indicates year 2020-2021)
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From: Baer, Bethany < >
Sent: Friday, January 08, 2021 10:08 AM
To: Hendrix, Brian * < >
Cc: Menschik, David < >
Subject: RE: Signal Management
Hi Brian,
Thanks for adding back on the list. I had been looking for it. Yes, we’d like the Covid19 (Moderna) and the Covid19 (Pfizer-BioNTech) added as
highlighted below. Nothing else on the list needs to be added for this round.
Thanks!
Bethany
From: Hendrix, Brian * < >
Sent: Friday, January 8, 2021 10:00 AM
To: Baer, Bethany < >
Cc: Menschik, David < >
Subject: RE: Signal Management
Hi Bethany,
Not sure how it disappeared from the email, but here’s the full list. So I’ll add Pfizer and Moderna. Let me know if you want any of the flu
vaccines.
-Brian
VAX_NAME VAX_NAME_FDA FIRST_APPEARED
COVID19 (COVID19 (UNKNOWN)) COVID19 (COVID19 (UNKNOWN)) 12/30/2020
COVID19 (COVID19 (MODERNA)) COVID19 (COVID19 (MODERNA)) 12/23/2020
INFLUENZA (SEASONAL) (AFLURIA 03-04) INFLUENZA (SEASONAL) (AFLURIA) 12/23/2020
COVID19 (COVID19 (PFIZER-BIONTECH)) COVID19 (COVID19 (PFIZER-BIONTECH)) 12/17/2020
INFLUENZA (SEASONAL) (FLUZONE HIGH-DOSE QUADRIVALENT 14-15) INFLUENZA (SEASONAL) (FLUZONE HIGH-DOSE QUADRIVALENT) 12/17/2020
INFLUENZA (SEASONAL) (FLUZONE HIGH-DOSE QUADRIVALENT 17-18) INFLUENZA (SEASONAL) (FLUZONE HIGH-DOSE QUADRIVALENT) 12/9/2020
INFLUENZA (SEASONAL) (AFLURIA QUADRIVALENT 09-10) INFLUENZA (SEASONAL) (AFLURIA QUADRIVALENT) 12/3/2020
INFLUENZA (SEASONAL) (FLUENZ TETRA 20-21) INFLUENZA (SEASONAL) (FLUENZ TETRA) 11/24/2020
From: Baer, Bethany < >
Sent: Friday, January 8, 2021 9:58 AM
To: Hendrix, Brian * < >
Cc: Menschik, David < >
Subject: RE: Signal Management
Hi Brian,
We had decided to include the two brand names (Pfizer-BioNTech and Moderna) but not the COVID (no brand name category) for the Signals
table. So I think there should be two rather than three.
Is there some other category I am missing?
Thanks,
Bethany
From: Hendrix, Brian * < >
Sent: Friday, January 8, 2021 9:43 AM
To: Baer, Bethany < >
Subject: Signal Management
Hi Bethany,
I’ll plan to add the 3 Covid entries. Do we need any of the others?
-Brian
Brian Hendrix (contractor)
Commonwealth Informatics, Inc.
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Empirica Signal Support Team
Office Of Translational Sciences
FDA/CDER/OTS
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1
Data Mining Introduction*
• Statistical method for identifying disproportionality
(excess of reported adverse event [AE] for a product
relative to other products)
• Hypothesis generating
– Statistical signal of disproportional reporting (SSDR) ≠ safety signal
• Absence of disproportionality does not confirm absence
of safety signal nor negate a signal otherwise detected
DRAFT - DO NOT DISTRIBUTE
*Best Practices in Drug and Biological Product Postmarket Safety Surveillance for FDA Staff (November 2019; Draft). Available at
https://www.fda.gov/media/130216/download
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2
DE Data Mining Methods
• Empirica™ Signal software (Oracle)
• Calculates Empiric Bayes Geometric Mean (EBGM)
using observed to expected (O/E) vaccine-AE pair ratios
– EBGM derived from a statistical model (Multi-item Gamma
Poisson Shrinker; MGPS) that accounts for instability from
small numbers by “shrinking” O/E ratios*
• Results adjusted by gender, year received and age
• Vaccine-AE pairs ranked by lower 5% bound of CI of
EBGM (EB05)
• Standard threshold for SSDR: EB05 ≥2
DRAFT - DO NOT DISTRIBUTE
*Szarfman A, Tonning JM, Doraiswamy PM. Pharmacovigilance in the 21st century: new systematic tools for an old
problem. Pharmacotherapy. 2004 Sep;24(9):1099-104. doi: 10.1592/phco.24.13.1099.38090. PMID: 15460169.
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3
Limitations of Hypotheses Generated
by Data Mining Include:
• Impacted by stimulated reporting (e.g., V-safe program)
• Potential statistical interaction (e.g., If vaccines X and Y
often given concomitantly, statistical signal for vaccine X
and AE Z may be driven by vaccine Y)
• VAERS limitations (e.g., passive reporting, variable
reporting by report source, duplicate reports, missing
data etc.)
DRAFT - DO NOT DISTRIBUTE PSI-HHS-000008256450
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From: "Menschik, David" < >
To: "Zinderman, Craig E" < >
Subject: FW: CBER VAERS Signal Management Liaisons/Contacts
Date: Thu, 09 Sep 2021 14:02:21 -0000
Importance: Normal
Inline-Images: image004.png; image003.png
FYI
From: Menschik, David
Sent: Wednesday, September 08, 2021 3:43 PM
To: Szarfman, Ana < >
Cc: Hendrix, Brian * < >; Sydnor, James * < >; Lebow, William *
< >; Baer, Bethany < >; Siegel, Jeffrey <J >;
Stockbridge, Norman L < >; Narayan Nair ( )
< >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Ana,
I certainly understand where you are coming from. I can in general speak to the understandable concern that you raise
regarding stratifying by year. While we must limit conduct, analyses, and discussion of VAERS data mining to
CBER/OBE/DE, I can discuss this general issue a bit more.
We have previously thought about and discussed this issue, recognizing that the vast-majority of reports received in
VAERS this year have involved COVID-19 vaccines which could drive PT-vaccine disproportionately scores towards the null
by contributing substantially to the comparator group, particularly if there is a class-effect (e.g., if all COVID vaccines are
associated with the same adverse event). While you have laid out reasonable arguments (which had generally occurred to
us) why stratifying VAERS data by year raises new limitations in interpreting data output using existing methods, there are
sound reasons for retaining adjustment by year.
From an epidemiology standpoint, exposures and health outcomes (not to mention public perceptions, behaviors,
practices, etc. whether stimulated or not) can vary dramatically from one year to the next (independent of vaccinations)
and such disparities by year can increase with increasing number of years. For example, during the ‘COVID era,’ circulating
SARS-CoV-2 disease can drive a substantial increase in reported specific AEs, independently of AEs that may be associated
with vaccinations; these AEs would most likely be over-represented in individual COVID vaccine-AE disproportionality
scores if the comparison group were expanded to include reports from increasing time periods prior to the ‘COVID-era.’
On a related note, MedDRA terms are continuously being updated and can regularly have substantial updates introducing
new AE terms not available when reports were coded during prior time periods. For instance, this past week (under
version 24.1 release), a new preferred term (PT), “multisystem inflammatory syndrome” was added to MedDRA. Without
controlling for time (e.g., year) of vaccination, there would likely be inflated disproportionality for newer MedDRA AE
terms in association with COVID vaccines since an expanded comparison group would include substantially more VAERS
reports that have no chance of having such newer MedDRA terms due to being coded prior to the availability of such a
term.
We will plan to discuss internally within CBER/OBE/DE and with Commonwealth options and associated feasibilities,
impacts, etc. for potential approaches to addressing the year-stratification issue. Any further discussion on VAERS data
mining methods/findings outside my chain of command will have to be offline and in general terms, as well as without
reference to any specific VAERS vaccine-PT pair outputs.
Thank you for your understanding,
David
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From: Szarfman, Ana < >
Sent: Friday, September 03, 2021 5:50 PM
To: Hendrix, Brian * < >; Sydnor, James * < >; Menschik, David
< >
Cc: Lebow, William * < >; Baer, Bethany < >; Siegel, Jeffrey
< >; Stockbridge, Norman L < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Brian,
Thanks so much for the wonderful job you are all doing.
Hi David,
I noticed that you are Board Certified in Clinical Informatics. Congratulations!
Regarding the question I posted to Brian:
Why I am concerned about stratifying the VAERS data by year?
Most of the VAERS reports for 2021 are for the COVID-19 vaccines.
By stratifying by year you are only using one year of data.
For a sound data mining analysis, more than half of the reports need to be for other vaccines.
Usually the control group would have 5 or 10 as many cases as the products of interest.
If you only want to compare the 3 different COVID-19 vaccines with each other, this would OK, but the 3 vaccines
could be doing the same bad thing, and you would not know it.
By stratifying by year, the background would be composed by the covid-19 vaccines.
Astra Zeneca in their demo at the Accelerator meeting, presented data not stratified by year, for this same
reason.
Using the RGPS data mining algorithm vs MGPS
RGPS is much, much better at unmasking signals than MGPS.
It automatically identifies and corrects for confounders.
This is an important function to have, given the pandemic situation.
I hope we continue helping each other.
Let me know if you need further information.
--Ana
Ana Szarfman, MD, PhD, FAMIA,
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From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 3:24 PM
To: Szarfman, Ana < >; Sydnor, James * < >
Cc: Menschik, David <David.Menschik@fda.hhs.gov>; Lebow, William * < >; Baer, Bethany
< >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Ana,
Thank you for bringing this up.
Currently all of the VAERS DM runs are being stratified by year.
Given the large proportion of covid-19 events, we will need to look at this going forward.
I’ve copied David and Bethany here to make them aware as well.
-Brian
From: Szarfman, Ana < >
Sent: Friday, September 3, 2021 2:16 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Therefore the background will only be for covid-19 vaccines, instead of for other vaccines. Therefore, masking covid-19
vaccine signals that are common with these vaccines, but not common across other types of vaccines.
From: Szarfman, Ana
Sent: Friday, September 3, 2021 2:07 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
For VAERS. Over 95% of the reports in 2021 are for COVID-19 vaccines.
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 2:06 PM
To: Szarfman, Ana < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
For VAERS or across Signal in general?
From: Szarfman, Ana < >
Sent: Friday, September 3, 2021 2:06 PM
To: Hendrix, Brian * < >; Sydnor, James * < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Thanks Brian and Casey,
Are any of the DM runs being generated NOT BEING stratified by year?
From: Hendrix, Brian * < >
Sent: Friday, September 3, 2021 2:02 PM
To: Sydnor, James * < >
PSI-HHS-000008254472
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Cc: Szarfman, Ana < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Hi Ana,
Can you please let me know which runs you have concerns about? I can provide details of the run structures as needed.
Thank you,
Brian
From: Sydnor, James * < >
Sent: Friday, September 3, 2021 1:58 PM
To: Hendrix, Brian * < >
Cc: Szarfman, Ana < >
Subject: RE: CBER VAERS Signal Management Liaisons/Contacts
Brian,
Ana has a concern regarding the new CBER VAERS Data Mining and Signal Management runs regarding the possibility that
they may be stratifying by Year. I know that there were a number of discussions about the criterial for the runs, so I’m
fairly certain that we do not stratify by Year because of the issues with the background that would occur for the most
recent months. Please confirm briefly if you can so that Ana can approach David and Bethany with a little bit of
background. Thank you!
Best regards,
Casey Sydnor (contractor)
Commonwealth Informatics, Inc.
Empirica Signal Support Team
From: Sydnor, James *
Sent: Friday, September 3, 2021 1:54 PM
To: Szarfman, Ana < >
Cc: Hendrix, Brian * < >
Subject: CBER VAERS Signal Management Liaisons/Contacts
Ana,
As we discussed on the phone, you will need to reach out to David Menschik and Bethany Baer (contact info below) in
order to discuss your interest in the new CBER VAERS Signal Management runs. Please let Brian and me know if/how we
can help after you have discussed with David and Bethany. You can copy us on the correspondence with them if you like,
so that we can remain in the loop to know how the conversation is resolved. Best of luck and we wish you a wonderful
long weekend!
David Menschik, MD, MPH
Associate Director for Surveillance Informatics
Division of Epidemiology/Office of Biostatistics and Epidemiology
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Center for Biologics Evaluation and Research/FDA
Bethany Baer
Physician
Division of Epidemiology/Office of Biostatistics and Epidemiology
Center for Biologics Evaluation and Research/FDA
Best regards,
Casey Sydnor (contractor)
Commonwealth Informatics, Inc.
Empirica Signal Support Team
Office Of Translational Sciences
FDA/CDER/OTS
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From:
To:
"Menschik, David"
>,
"Zinderman,
Craig
E"
Bee: "Menschik, David"
Subject: Coverage through 8/18
Date: Fri, 05 Aug 2022 12:22:50 -0000
Importance: Normal
Embedded: unnamed
Hi Meghna and Craig,
Thanks very much for covering me while I’m out from 10:30 am today through 8/18 (MA: covering through Friday 8/12; CZ
covering through 8/18).
1. Meetings:
a. AE Weekly status meeting on 8/12 (MA)
b. GDIT Composite Report WG 8/16 (CZ)
2. COVID vaccine dose data - Post (drag and drop) spreadsheets from CDC email to Team folder
3. 2Jynneos dose data — John/Tom indicated plan to have this available similar to COVID vaccine dose data and indicated
they would similarly share with us (pending)
4. Jynneos data mining —| shared results from Empirica summary table (signals tab) once per attached email. | check this
weekly and would plan to share with Tom/John if new PT(s) appear in the table.
5. Melvyn has a list of tasks for which he should be independent with exception of TARS queries/reports and will be
working with Chris Jason on this. Melvyn knows that #1 priority is ‘customer service’ including timely responses to
requests for help with BO queries. Please don’t hesitate to ask him for help with any BO query.
Thanks again,
David
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From: "Menschik, David"
To: "Shimabukuro, Tom (CDC)" >, "Su, John (CDC)" <>
Cc: "Zinderman, Craig E" >, "Nair, Narayan"
Bee: "Menschik, David"
Subject: Jynneos DM
Date: Tue, 02 Aug 2022 11:35:17 -0000
Importance: Normal
Attachments: USST_JTYNNEOS_20220729.xls
Good morning Tom and John,
As per recent leadership meeting request, attached please find a list of all (i.e., unvetted, regardless of
notability, etc.) PTs with data mining alerts (i.e., EBO5 >2) for Jynneos VAERS reports from our weekly ‘US Signals
Summary Table’ (‘as of date’ 7/29/22). Please feel free to share this hypothesis generating output with your
team/command chain, though this is not intended to be shared more broadly.
Thanks,
David
‘THIS MESSAGE, INCLUDING ANY ATTACHMENTS, IS INTENDED ONLY FOR THE USE OF THE PARTY TO WHOM IT IS ADDRESSED AND MAY
CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL, AND PROTECTED FROM DISCLOSURE UNDER LAWIf you are not the addressee, or a
person authorized to deliver the document to the addressee, you are hereby notified that any review, disclosure, dissemination, copying, or other action based on the
content of this communication is not authorized If you have received this document in error, please immediately notify the sender immediately by e mail or phone
PSI-HHS-000008256551
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From: "Baer, Bethany"
To: "Niu, Manette"
Ce: "Menschik, David"
>,
"Zinderman,
Craig
E"
Subject: RE: Data mining
Date: Tue, 16 Mar 2021 23:00:24 +0000
Importance: Normal
Sounds good. Thanks, Manette.
Bethany
Sent: Tuesday, March 16, 2021 6:38 AM
To: Baer, Bethany >
Cc: Menschik, David >; Zinderman, Craig € <n>
Subject: RE: Data mining
Bethany,
Craig and | discussed this issue yesterday. I’ll try and set up a meeting for us to meet with Ana to discuss her VAERS
objectives/rationale.
Thank you!
Manette
From: Baer, Bethany -—tti‘C:Cs~s*~*S*~*@
Sent: Sunday, March 14, 2021 5:11 PM
To: Zinderman, Craig E >; Niu, Manette ;-t—‘isSOCi
Cc: Menschik, David
Subject: RE: Data mining
Thanks, Craig. | understand that this is a complex issue and | just wanted to make sure you all were involved and aware of
the situation. Her comments were only made on the CDER/CBER call with the contractor, Commonwealth, and were brief
mentions. Potentially, she was just brainstorming and theorizing, but it struck me as unusual compared to the typical
topics covered on the call. She has been at FDA a long time and involved in many projects, so | would certainly hope that
she would reach out to someone in CBER to collaborate if she did want to move forward with something. Ajoint project
could be great. | have had only limited interactions with Ana during CDER/CBER Empirica calls so | do not know her well. |
know that she knows a lot more about data mining than | do!
Thanks,
Bethany
Sent: Friday, March 12, 2021 3:08 PM
To: Baer, Bethany >; Niu, Manette 5 tt—“‘“—i“‘; <CO';tr
Cc: Menschik, David >
Subject: RE: Data mining
Bethany:
| can understand your concerns, but I’m not sure that there is an obvious solution. Refusing her access just for vaccines
seemsa little disingenuous since she has full access to FAERS data for all of CBER’s >200 non-vaccine products. Seems
reasonable to try to understand why she wants to use VAERS data instead of her own Center’s data, and to caution her
that while its fine for her to do methodological work, we aren’t interested in additional data mining studies of COVID data
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outside of CBER’s usual processes. Did she make these statements publicly? Is there someone who has some sort of
relationship/collaboration with her that could approach her on these issues? I don’t know her and don’t have any
interactions with her. Anyone know who she works for?
Thanks,
Craig
From: Baer, Bethany < >
Sent: Friday, March 12, 2021 12:42 PM
To: Zinderman, Craig E < >; Niu, Manette < >
Subject: RE: Data mining
Hi Craig and Manette,
The funding/payment issue is still being looked into by Judy. After a little more thought, I wanted to be sure I clearly
raised my other concern. If Ana is not working on a specific project with someone in our office, is there justification for
her to have access to the VAERS data in Empirica? As I mentioned in the earlier email, on the Empirica CDER/CBER calls
she has twice now expressed interest in the COVID vaccine data mining and made some broad statements that I don’t
think DE would agree with (e.g., indicating that the vaccines are causing ITP). If she is not working with someone in OBE,
who is coordinating the direction of the inquiries and working to interpret the results? Who would provide clearance for
sharing the information? Factors such as GDIT VAERS report processing backlogs, and other outside issues, would be
important to consider when looking at this data and may not be widely understood outside of DE. Since we typically only
give Empirica CBER access to DE medical officers or other CBER members working on specific projects, I defer to you both
regarding this. I know Ana worked to develop the data mining system and this might be a special circumstance due to her
knowledge and experience. In the last year, she was working on a duplicate detection algorithm with FAERS reports in
Empirica that involved some CBER examples, so there might be administrative reasons why she needs the extra access. I
wanted to make sure I had expressed my concerns based on what I had heard on some recent calls.
Thanks,
Bethany
From: Baer, Bethany
Sent: Thursday, March 11, 2021 5:51 PM
To: Zinderman, Craig E < >; Niu, Manette < >
Subject: RE: Data mining
Yes, that is helpful. Thanks, Craig. There were some other emails between Judy and CBER/CDER contracting/funding folks
that involved trying to coordinate payments for several different projects. In the end, it sounded like, due to other forces,
CDER had to already make the payment and things couldn’t be balanced out this year for this between the two centers. I
will check in with Judy about the bottom line regarding that. Right now, we will leave Ana’s account as is with a CBER
login.
Thanks,
Bethany
From: Zinderman, Craig E < >
Sent: Thursday, March 11, 2021 3:24 PM
To: Baer, Bethany < >; Niu, Manette < >
Subject: RE: Data mining
Hi Bethany:
I spoke to Manette about this yesterday. While Ana has spoken to Manette about the work that Manette describes below,
sounds like Manette isn’t actively engaged in working on a collaboration or project. So, I would say that we don’t have a
business need to pay for an account for Ana.
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However, I would think that we have no objections to her having access/ a CBER account. So, if the payment issue is no
longer a problem, then its fine for her to have this access. If CBER is expected to pay, then I think we would not be able to
justify the cost of her account (unless the payment is minimal and non-consequential enough that CBER won’t need us to
justify).
Does that help?
Thanks,
Craig
From: Baer, Bethany < >
Sent: Thursday, March 11, 2021 2:43 PM
To: Niu, Manette < >; Zinderman, Craig E < >
Subject: RE: Data mining
Hi Manette and Craig,
It sounds like the payment issue is less of an immediate concern due to some arrangements between CDER and CBER, but
I wanted to reconfirm that you would like Ana Szarfman to have a CBER Empirica account and access to VAERS through
Empirica. The way Kosal has set it up, she has a CBER login. On some larger Empirica contractor calls recently, she has
expressed interest in using COVID vaccines as an example of data mining and sharing results for training purposes within
the FDA. I wasn’t sure the process for how that would happen and if DE was wanting to do that with such new products
with potentially actively changing safety profiles.
Thanks,
Bethany
From: Niu, Manette < >
Sent: Wednesday, March 10, 2021 1:24 PM
To: Zinderman, Craig E < >
Cc: Baer, Bethany < >
Subject: FW: Data mining
Craig,
The background for this: Ana approached me several months ago as she is interested in testing a new process in VAERS
based on new methodology proposed by Bill DuMouchel for data mining focused on signal detection for concomitant
medication use. (I did ask Steve if it was alright to grant Ana VAERS access, and he agreed). The project she proposes is
very preliminary in the exploratory-hypothesis stage (no protocol).
Thank you!
Manette
From: Niu, Manette
Sent: Wednesday, March 10, 2021 1:14 PM
To: Nguon, Kosal * < >
Subject: RE: Data mining
Will CBER or CDER pay for this account?
From: Nguon, Kosal * < >
Sent: Wednesday, March 10, 2021 1:11 PM
To: Szarfman, Ana < >; Niu, Manette < >
Cc: Sydnor, James * < >
Subject: RE: Data mining
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Hello Manette and Ana,
Ana has a user license through CDER, and the CDER/CBER designation is for purposes of tracking and paperwork. Ana is
listed as a “CBER” login user as this is the only feasible avenue to provide access to both FAERS and VAERS data. We may
have to move Ana back to the CDER login group for the annual user review and we can move her back to CBER afterwards
, but it should be of minimal impact. I believe everyone was in agreement that Ana should have access to VAERS data.
Thanks to you all for your patience and understanding.
Best,
Kosal
From: Szarfman, Ana < >
Sent: Wednesday, March 10, 2021 12:54 PM
To: Niu, Manette < >
Cc: Nguon, Kosal * < >
Subject: RE: Data mining
As far as I can understand, I have access as a CDER user. I added Kosal in the cc because he did the programming
assessment.
From: Niu, Manette < >
Sent: Wednesday, March 10, 2021 12:52 PM
To: Szarfman, Ana < >
Subject: RE: Data mining
Great, this is through CDER, correct?
From: Szarfman, Ana < >
Sent: Wednesday, March 10, 2021 12:51 PM
To: Niu, Manette < >
Subject: RE: Data mining
Yes, I now have access to the VAERS data.
From: Niu, Manette < >
Sent: Wednesday, March 10, 2021 12:49 PM
To: Szarfman, Ana < >
Subject: RE: Data mining
Ana,
Do you have access to VAERS in your Empirica account?
Thank you!
Manette
From: Szarfman, Ana < >
Sent: Wednesday, March 10, 2021 12:47 PM
To: Niu, Manette < >
Subject: RE: Data mining
Hi Manette,
Thanks you for addressing this issue! I just got access.
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Do you want to participate in the meetings with Bill DuMouchel?
From: Niu, Manette < >
Sent: Wednesday, March 10, 2021 12:45 PM
To: Szarfman, Ana < >
Subject: Data mining
Ana,
Were you able to get your CDER Empirica account set up?
Thank you!
Manette
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From:
To: >,
"Zinderman,
Craig
E"
Ce: "Stockbridge, Norman L" >, "Ryan, Qin"
a
Subject: Our conversation about VAERS of this afternoon.
Date: Fri, 26 Mar 2021 19:48:39 +0000
Importance: Normal
Attachments: CovidWeek9MaskExamples.xls; AllCovid.zip; Ana_Szarfman_-
_Briefing_ofDr_Peter_Marks - March _1_2021_at_100_PM..pdf
Inline-Images: image003.png
Hi Manette, Beth, and Craig,
Please refer to the attached files that | displayed this afternoon.
As we talked, the attached excel comparisons between RGPS and MGPS were generated by Bill DuMouchel using the
VAERS public domain data incorporated into Empirica Signal.
RGPS is included with the public domain version of Empirica Signal.
Bill and | extensively studied the increased value of RGPS over MGPS for reducing false positives and negative signals.
Oligonucleotides (regulated by CDER) and mRNA vaccines (regulated by CBER) share some common important
characteristics, including severe thrombocytopenia; and we are interested in using several resources to understand them
better.
Qin Ryan, in the cc is the principal investigator of a project studying this effect with oligonucleotides, having me as a
collaborator.
VAERs offers a unique opportunity to study the value of RGPS in improving the detection of early signals in a different,
important environment during a pandemic situation whereas the early detection of novel signals is tremendously
important for all.
The new methodology being proposed by Bill to study across multiple applications offers the opportunity to benefit from
automation, immediate access to a cross comparison of safety signals across multiple treatment arms within multiple
applications, and the identification of unbalanced risk factors at baseline. Qin Ryan worked with an earlier prototype of
the system, and will answer questions that you may have.
Let me know if you need any additional feedback.
Warmest regards and thanks,
~-Ana
Ana Szarfman, MD, PhD, FAMIA,
Diplomate by the American Board of Pathology in both, Clinical Pathology (1984) and Clinical Informatics (2017), and
Fellow of the American Medical Informatics Association (2020)
Medical Officer, Safety Data Mining Developer and Medical Informatics Analyst,
PSI-HHS-000008257443
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Celebrating nearly a quarter of a century of successful implementation of safety data mining, interactive patient profiles,
and other automated analytical tools.
Division of Cardiology and Nephrology, OCHEN, Center for Drug Evaluation and Research, Food and Drug Administration
From: Bill Dumouchel >
Sent: Wednesday, March 24, 2021 9:38 AM
To: Szarfman, Ana < >
Subject: [EXTERNAL] Fw: WVAERS 2021W09 data loaded to slc06lhx
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the
sender and know the content is safe.
From: Bill Dumouchel < >
Sent: Tuesday, March 23, 2021 4:27 PM
To: Steve Bright < >; Rave Harpaz < >; Szarfman, Ana
< >
Cc: Mohammad Al-Ansari < >; Alexander Nip < >
Subject: Re: WVAERS 2021W09 data loaded to slc06lhx
I created runID#307 which is the same as #304 but with the new data.
I'm attaching an excel file with 49 examples of extreme masking--that is, RGPS shows a signal where MGPS
doesn't, and the confidence intervals don't overlap.
The Covid custom term is just a label for any covid vaccine, no matter the manufacturer. Most of the significant
masking involves that, because it gets a larger sample size and thus shorter confidence intervals, with less
chance for overlap.
My main worry about these seemingly significant adverse events it that the age grouping is quite course,
agegroup6 lumps everyone over 65 together.
So our adjustment for age may not be good.
Appendicitis doesn't show up with the extreme requirement that I imposed on the above search, but, relaxing it
slightly, there are fairly extreme estimates for Pfizer & Appendicitis, as shown in sheet two of the attached excel
file.
Finally, I've attached a zip file that contains all of the covid-AEs in the results of the run. (50,515 rows)
Enjoy!
Bill
PSI-HHS-000008257444
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
— Page 168 of 197 —
From: Ruixia Song < >
Sent: Monday, March 22, 2021 11:26 AM
To: Bill Dumouchel < >; Steve Bright < >; Rave Harpaz
< >
Cc: Mohammad Al-Ansari < >; Alexander Nip < >
Subject: WVAERS 2021W09 data loaded to slc06lhx
Hi All,
WVAERS 2021W09 data has been loaded to slc06lhx.
Ruixia
PSI-HHS-000008257445
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I am humbled and thankful for the
tremendously difficult and amazingly hard
work you are all doing and for all your
successes
Many thanks for your invitation to exchange thoughts
1PSI-HHS-000008259547
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Mortality data to address the COVID-19 public health
and analytical needs of the users of the information
More timely detection of adverse events and
associated risk factors that we may not know how to
formulate a priori
Ana Szarfman, MD, PhD, FAMIA, Medical Officer, Diplomate by the
American Board of Pathology in both, Clinical Pathology (1984) and
Clinical Informatics (2017), Safety Data Mining Developer and Medical
Informatics Analyst, Division of Cardiology and Nephrology, CDER, FDA
Dr. Peter Marks Briefing, February 29, 2021
2PSI-HHS-000008259548
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Mortality data linked to EHRs and Claims
data
3PSI-HHS-000008259549
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• There is no universal tool to CENTRALLY capture mortality data
in the U.S.
• Multiple surveillance and analytical systems cannot easily access
data on
DEATHS OCCURRING IN AN OUT-OF-HEALTHCARE SETTING
using EHRs or claims data.
• If a patient
DIES WHILE IN THE HOSPITAL,
the death will be coded
as such in the EHR,
but not if the death occurs with patients being
discharged to hospice care, to a nursing home, or to their home.
• When such information is needed for RESEARCH or to be linked to
CLAIMS data (such as BCBS), it is typically obtained from
PRIVATE
SERVICES who collect the information from various sources likeFUNERAL HOMES AND OBITUARIES IN LOCAL NEWSPAPERS. (a very
time consuming and very inefficient process)
4PSI-HHS-000008259550
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• Deaths occurring at home, on the street, or when the subject is
homeless, as well as autopsies are not treated as medical clinical
service events.
• The death certificate information does not get back to the medical
record.
• Death certificates are notoriously sparse and incomplete.
• They are collected by a multitude of governing localities, and then
gathered by the State. The types of reportable deaths are
determined by federal, state or local laws.
5PSI-HHS-000008259551
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• The States receive the certificates and submit them to the National
Death Index (NDI) where they get adjudicated and added to the
NDI final file annually.
• The NDI website provides death information to researchers; but the
process requires funding support
:
https://www.cdc.gov/nchs/data/ndi/ndi_application.pdf
https://www.cdc.gov/nchs/ndi/portal.htm
• These requests are usually applied to 500 patients in a research
project or clinical trial.
We need mortality data for over 300 million individuals
6PSI-HHS-000008259552
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• Clinical trials contain COMPREHENSIVE AUTOPSY information but not
the EHRs.
• Registries, like cancer registries or transplant registries systematically
collect death information, but they represent relatively small siloes of
information disjoined from EHRs.
• CMS and DoD and VA hospitals GET FEEDBACK SEEDS from the SSA ofDEATHS THAT NEED TO BE REMOVED FROM THEIR BENEFICIARY LIST.
•
NOT SURE HOW OPTIMIZED THESE SYSTEMS ARE FOR INCLUDING DEATHS IN
THEIR ANALYSES OF CLINICAL DATA.
• Outside these Federal systems, the SSA STOPPED MAKING THIS
INFORMATION AVAILABLE 5 YEARS AGO because of a potential for fraud
(people applying for loans using fake Social Security codes) and would only
typically provide an answer for a specific person, and inform when and how
they died.
7PSI-HHS-000008259553
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• Death information IS NOT CONSIDERED PRIVATE HEALTH
INFORMATION. IT IS PUBLIC INFORMATION.
• Family members, life insurance companies, and voter registrations
are granted such access.
• The key problem is that this information is not collected and made
available in a timely way.
• If there is a time, it is now for the Federal Government to act and
improve the ability to centrally collect death information or to
expedite the link of NDI information to address the necessary
research and public health needs of all the analysts of the
information.
• The government can define the requirements and precautions that
the receiving parties will need to put in place to avoid fraud.
• The government can also monitor and prevent fraud activity.
• Correction of this situation will require awareness of this problem,
know-how, efforts, funding, and regulatory support.
8PSI-HHS-000008259554
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The superior performance of the RGPS
algorithm for data mining spontaneous
reports, currently only available outside the
FDA and CDC
There is a contracting mechanism in place at
the FDA to solve this problem quickly
9PSI-HHS-000008259555
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10PSI-HHS-000008259556
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The graph showing the signals of 3 Sector
Maps next to each other is quite interesting
• The PRR on the left highlights almost everything
• The MGPS on the right is flat (you are not getting useful
information with such low counts)
• The RGPS in the middle looks more informative for follow-up
evaluation
• This is because RGPS can better adjust for both, masking (false
negatives) and confounding (false positives).
11PSI-HHS-000008259557
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12PSI-HHS-000008259558
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Only to highlight an “Appendicitis, perforated”
signal with the Pfizer vaccine that may require
follow-up evaluation
13PSI-HHS-000008259559
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14PSI-HHS-000008259560
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The MGPS data mining method currently in
use at the Agency and at the CDC is not the
state of the art
RGPS is the state of the art:
• Is a regression-based extension of MGPS that incorporates more
information into the signal generation process. This leads to a lower
rate of missed signals and less false alerts.
• Removes the effect of products whose strong signals in the background are
overwhelming the signals of the product of interest and thus uncovers signals of
products being masked (the false negatives.)
• Adjusts for the concomitant products in the same reports having strong signals
to remove the confounding that generates false positives with innocent
bystander products.
15PSI-HHS-000008259561
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VAERS doesn’t code concomitant medications,
while FAERS does
• If we would also adjust for the concomitant meds in the
narratives of VAERS reports, we could improve the estimate of
confounding (false alerts or false positives) even better.
• Bill DuMouchel, who developed both, MGPS and RGPS is
planning to extract and code the drugs in the narratives of VAERS
reports to reduce confounding.
• Note also that REPORTS FOR THE ASTRA ZENECA VACCINE IN USE
IN THE U.K. arrive to the FAERS data instead of arriving to the
VAERS data.
16PSI-HHS-000008259562
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
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Simultaneous, automated identification of
adverse events and risk factors from
multiple products in multiple clinical trials,
that we may not know how to specify a
priori
This is a new analytical approach by Dr. Bill
DuMouchel that will require funding
17PSI-HHS-000008259563
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
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Analysis of adverse event data (as opposed to
efficacy) from studies of medical products
involve several difficult problems
• Pre-specification of analysis end points are rarely possible for adverse
events, leading to a multiple comparisons challenge whenever many
different adverse events show up.
• Rare adverse event issues often show up with small counts that could
be grave dangers to public health.
• Data from many clinical trials and observational studies may need to
be analyzed jointly, such as for many newly developed products.
18PSI-HHS-000008259564
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Risk prediction for diseases for which we do not
understand the trajectory of individual patients
is low
• There is a need for a statistical method capable of identifying rare,
unbalanced risk factors that not only occur during or after treatment, but
also, more importantly, at baseline.
• Consistent efficacy and safety signals may remain hidden in disjoined
clinical trial applications or by analyses that do not properly adjust for
multiplicity and small counts across all the data being generated.
• We need to implement a solution that will allow for display of the adverse
event information and results of analyses in an interactive and user-
friendly way that will not require a continuous and impossible-to-
document customizations of the complex data and the analytical tools.
19PSI-HHS-000008259565
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Advantages of having this automated, intuitive,
and interactive analytical program in place
• Can perform of analysis of patient level data from many clinical trials
and many applications at once.
• The addition or removal of some data will generate a quick analysis
WITHOUT HAVING TO DO A LOT OF INTERMEDIATE ANALYSES and
redo a meta-analysis based on the new summary statistics.
• Can provide TRANSPARENCY to the decision-making process and
enable RAPID RE-ASSESSMENT OF THE DATA FOR INCREASED
COMPREHENSION of new and evolving issues of interest
20PSI-HHS-000008259566
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Comparing different treatments that do not
all appear in any one study
• This approach will compare subgroups based on multiple
treatment arms, covariates, and endpoints measured on each
patient.
• All this would usually require an analysis of the patient level data
in order to fit the Bayesian shrinkage model.
• T HESE ACTIVITIES NEED TO BE DONE EXPEDITIOUSLY, IN A TRANSPARENT WAY
TO AVOID PUBLIC CONFUSION
• WE HAVE NEVER BEEN ABLE TO CONDUCT SUCH ASSESSMENTS,
AND EVEN LESS TO CONDUCT SUCH ASSESSMENTS IN AN
INTUITIVE AND AUTOMATED MANNER.
21PSI-HHS-000008259567
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Eight Studies of the ICPI Nivolumab versus other
Active Comparators -- How to compare the various
treatment effects?
Study ARM 1 Arm 2
37
NIVOLUMAB
INVESTIGATOR CHOICE
17 DOCETAXEL
25 EVEROLIMUS
57 DOCETAXEL
66 DACARBAZINE
26 INVESTIGATOR CHOICE
41 INVESTIGATOR CHOICE
27 CHEMO
22PSI-HHS-000008259568
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Comparison: Pool All 8 Studies Into 1
Analysis For 11 Safety HLTs
23PSI-HHS-000008259569
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AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
Representing a Pool of Studies as a Network
Lines Connecting Two Arms Represent within-Study Comparisons (numbers=study
multiplicity)
Everolimus
Docetaxel
a
Nivolumab
LT
Dacarbazine
a
Chemo Investigator
Choice
PSI-HHS-000008259570
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Docetaxel
Endpoints
HLT1, HLT2, HLT3, ...
Chemo
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
Each Patient May Have Multiple Medically
Similar Endpoint Measurements
Endpoints
HLT1, HLT2, HLT3, ...
SO
_—————
Dacarbazine Nivolumab
ZN—
Endpoints
HLT1, HLT2, HLTS3, ...
Investigator
Choice
Everolimus —_
Endpoints
HLT1, HLT2, HLTS, ...
Endpoints
HLT1, HLT2, HLTS3, ...
Endpoints
HLT1, HLT2, HLT3, ...
PSI-HHS-000008259571
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
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AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
Each Patient May Have Multiple Covariates
Possibly Influencing Endpoints or Treatment
Effects
Docetaxel
a
Covariates
Age, Gender, Race,
Concom. Meds, ...
Chemo
~
Covariates
Age, Gender, Ra
Concom. Meds, ...
ce,
Nivolumab
a
m—~
Covariates
Age, Gender, Race,
Concom. Meds, ...
a
Everolimus —_|
Covariates
Age, Gender, Race,
Concom. Meds, ...
Covariates
Age, Gender, Race,
Concom. Meds, ...
_—————
Dacarbazine
NN Investigator
Choice
Covariates
Age, Gender, Race,
Concom. Meds, ...
PSI-HHS-000008259572
AUTHORIZED FOR PUBLIC RELEASE BY CHAIRMAN JOHNSON
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Thanks to your work, there are now in place
multiple approaches for passive and active
surveillance for post-authorization safety
signals assessments
27PSI-HHS-000008259573
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— Page 196 of 197 —
Some critical roadblocks to consider:
• Claims not collecting vaccinations in a
systematic way to understand who gets
vaccinated and with which vaccine.
• No direct link/access to dead registries or
EHRs to understand cause of death and
underlying risk factors.
• Viral variants need to be associated with
particular clinical profiles, a task that
requires the maintenance of a high level
of clinical data veracity. However,
• There is a lack of a universal proactive
definition and application of permissible
variables and values in EHRs and of
unique IDs for patients (linked to
providers and health facilities) that will
simplify access to such data.
• There are incomplete and not standardized
data creation practices in place within and
across systems that unnecessarily delays the
analytical processing.
• There are no simple ways to follow
individual patient progression in EHRs and in
other sources of data
Potential improvements:
• For passive surveillance:
• RGPS will provide a big advantage over
MGPS for signal detection
• For active surveillance:
• The simultaneous automated assessment
of safety data from multiple clinical trials
and OD -- and associated risk factors that
we may not be able correctly specify a
priori -- will provide a great analytical
advantage
28PSI-HHS-000008259574
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Zip archive written by user: Bill DuMouchel on: 03/23/2021 20:20:58 UTC
Source Data: VAERS data as of March 05 of 2021 from www.vaers.hhs.gov loaded on 2021−03−07 00:00:00.
0
PSI-HHS-000008262033
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