Dr. Gerald’s Latest Analysis of AZ’s COVID Trajectory

University campuses remain an area of concern while broader trends continue to improve.

Summary of Dr. Gerald’s Analysis:

• Arizona is transitioning to a new phase of the outbreak where viral transmission is declining in the working-age and older adult populations but increasing among adolescents and young adults. This change is most likely attributable to re-opening of university campuses.

o Rising cases on university campuses pose an unknown risk to the broader community as it is unclear to what extent that the social networks of students and the broader community overlap.

o While the risk of severe disease in young adults is low, that is not the same as no risk. As case counts increase, some young adults will invariably require hospitalization and it is not out-of-the question that a small number of deaths could result.

o Reporting lag for PCR results has improved such that ≥90% of results are returned within 48 hours; however, the rapid rise in saliva testing on university campuses presents new challenges in data reporting and interpretation.

• Outside of young adults, levels of community-driven viral transmission are on par with those observed in mid-May just before Arizona re-opened its broader economy.

o For all locales, mask-wearing ordinances will be needed for the foreseeable future to mitigate the spread of Covid-19.

o As additional actvities (e.g., schools and businesses) resume, they will bring more people into closer contact and will facilitate additional viral transmission. Therefore, continued adherence with mask wearing, physical distancing, hand hygiene, and surface decontamination will be needed to mitigate these risks.

• Covid-related hospital utilization continues to decline while excess capacity is not being replenished owing to larger amounts of non-Covid care. However, adequate capacity is available for the foreseeable future.

o From now until January, non-Covid hospitalizations are expected to increase putting additional strain on hospital capacity.

o Hospitals will continue to experience large volumes of elective care to address the backlog of patients waiting elective procedures.

• Current Covid-19 test capacity appears adequate as evidenced by quick turn-around for PCR results and a PCR test positive percentage of 4% which is within the recommended 3 – 5% threshold.

o As more Covid-19 testing transitions to saliva testing, it is unclear how this might impact test positivity trends. A rising test positive percentage should raise the possibility of resurgence.

Next update scheduled for September 18.

County Data (weekly crude and population-adjusted cases counts) appear in Appendix.

AHCCCS Takes the Initiative in Suicide Prevention

This week is National Suicide Prevention Week. Suicide in Arizona is the 8th leading cause of death, with certain groups at higher risk. This essential public health work is run by AHCCCS. The team has grown to four employees in the last year – each managing a different aspect of the work.  

The team’s rallying cry is to prevent suicides, we must all participate. Some opportunities to do so include

Get trained in an evidence-based suicide prevention training. The Arizona Department of Education is offering free online training (QPR). This training meets the requirement for the Mitch Warnock Act, which goes into effect this fall.

Speaking of the Mitch Warnock Act, which requires school staff who work with students between 6-12th grades to be trained in suicide preventions – ask some tough questions. What is your student’s school doing to meet the new mandate? Do they have a training in place? A tracking mechanism? Do they have a suicide prevention policy on their district website? Does your student’s school have a behavioral health provider on campus? If school leaders don’t have answers, refer them to the AHCCCS team. (Contact information below.)

Do you know of someone who needs crisis counseling, or is feeling depressed? www.resilientarizona.org is a new, free resource for anyone in Arizona who may need to talk to someone. You can also call 2-11 for these services.

And the easiest way to get involved in suicide prevention? Check in on your neighbors, friends, and family – especially those who live alone. Isolation is a risk for suicide. A simple hello can go a long way to helping someone feel cared for.

The AHCCCS suicide prevention team:

Zeruiah Buchanan is the state suicide prevention epidemiologist. She is working closely on health equity to ensure all Arizonans have the ability to access necessary behavioral health services.

Brian Planty is the Project AWARE suicide prevention lead. He serves as the AHCCCS liaison with their partnership with the Arizona Department of Education on this five-year grant that brings suicide prevention and behavioral health resources to schools.

Albert Swanson manages a new $800k emergency suicide prevention grant that brings together domestic violence and behavioral health services in Pima County.

Kelli Donley Williams, the AzPHA treasurer, leads the team and oversees AHCCCS’ push to have behavioral health providers in schools statewide. Contact the team: [email protected]

Thank you for your leadership!

How Are New Vaccines and Drugs Approved?

Could the SARS CoV2 Vaccines Take a Short Cut?

The U.S. has an organized way of approving new vaccines and drugs for use and regulating them once they’re approved. However, during public health emergencies, the FDA is allowed to provide for short cuts. This week we explore the normal approval process, investigational new drugs, and the Emergency Use Authorization process which can be used in public health emergencies.

Normal Approval Processes

A key player in the process of approving new drugs is within the FDA’s Center for Drug Evaluation and Research. The center’s job is to evaluate new drugs before they can be sold. Their core mission is to ensure that drugs work and that their health benefits outweigh their known risks.

The first step in getting a new drug or vaccine approved is testing it in clinical trials. Drug companies do that testing and send their evidence to the Center.  Next, a series of tests (clinical trials) determines whether the vaccine or drug is safe when used to treat a disease and whether it provides a real health benefit.  Basically, do the benefits of the vaccine exceed the risks?

That’s where the independent review comes in. The FDA Center for Drug Evaluation and Research has a team of physicians, statisticians, chemists, pharmacologists, and other scientists that review the company’s data and proposed labeling. This is an independent review to make sure that a vaccine’s health benefits outweigh its known risks. If a drug or vaccine is considered safe and effective, then it can proceed through the approval process.

Part of the approval process includes developing a Package Insert that describes how the drug or vaccine should be used. The Package Insert has 2 main parts, the “highlights of prescribing information” and the “full prescribing information”. Together this information provides clinicians with access to the information they’ll need to responsibly prescribe the medication.

Clinicians that prescribe drugs are encouraged (but not required) to follow the instructions in the package insert. Clinicians can use professional judgment as they prescribe the drug and can decide to use a drug in a way that’s different from what is described in the Package Insert. When clinicians do this, it’s called prescribing off-label.

Prescribing off-label also has its risks. One obvious one is that since the clinician is prescribing in a way that may not be well-researched, he or she may be taking a risk with their patient.  Also, if a patient has a bad outcome, the prescriber’s actions will be measured against the standard of care…  and one tool considered by the courts in damages lawsuits is whether the clinician was prescribing according to the package insert.

Investigational New Drugs

The Investigational New Drug program allows drug makers to get permission to start human clinical trials before a drug or vaccine is approved. Drug makers or researchers file an application with the FDA that discloses the pre-clinical testing, manufacturing information, investigator information, the clinical trial protocols, and commitments to get informed consent.

If an investigational new drug application is approved, then the researchers can begin using the drug, but they’re supposed to stay within the boundaries of their application and be diligent and measure and report their findings.

An example of an investigational new drug for COVID-19 is convalescent plasma (plasma donated by folks that have recovered from COVID-19). Applications for using convalescent plasma were authorized in early April to fill an urgent need to provide patient access to a medical product when FDA was working with researchers to facilitate randomized clinical trials to study convalescent plasma.

Emergency Use Authorization

Another process by which new drugs or vaccines which aren’t yet approved is called an Emergency Use Authorization (EUA). An EUA doesn’t constitute approval of a drug, but facilitates availability of an unapproved drug (or an expressly unapproved use of an approved drug).  EUAs can only be used during a state of emergency (as is the case right now with the COVID-19 pandemic).

The standard for approval of an EUA is lower than a regular approval of a drug. All the applicant needs to show is that it’s “reasonable to believe” that the drug (or vaccine) “may be effective to prevent, diagnose, or treat serious or life-threatening diseases”.

Over the course of the pandemic, the FDA has approved scores of drugs, tests and medical devices under EUA protocols including Drug and Biological ProductsIn Vitro Diagnostic ProductsHigh Complexity Molecular-Based Laboratory Developed TestsSARS-CoV-2 Antibody TestsPersonal Protective Equipment and Related Medical Devices, and Ventilators and Other Medical Devices.

For example, last week the FDA approved convalescent plasma under an EUA. The FDA cited what was learned about the efficacy and safety of convalescent plasma in the authorized Investigational New Drug studies.

The EUA was issued despite the fact that COVID-19 Treatment Guidelines Panel concluded that there are insufficient data to recommend either for or against the use of convalescent plasma for the treatment of COVID-19 and that plasma should not be considered the standard of care for the treatment of patients with COVID-19. For more information, please read the full statement on the COVID-19 Treatment Guidelines website.

Another example is hydroxychloroquine. A couple of months ago the FDA authorized the use of hydroxychloroquine as a treatment for COVID-19 under an EUA. However, the FDA later removed the EUA after evidence was discovered that the harms of using hydroxychloroquine for treating COVID-19 exceeded the benefits.

Which Path will COVID-19 Vaccines Take?

Every vaccine in use so far has gone through the traditional FDA approval process. Phase I, Phase II and Phase III followed by the traditional data review process. Vaccines have needed to establish that they are safe and effective and publish that data publicly. If the review is successful it is approved. Sometimes the vaccine is approved for just certain populations. 

For example, the first time the HPV vaccine was approved it was licensed just for females because they only tested the vaccine in women. That has since been expanded to males after additional clinical trials and a modified approval process.

The COVID-19 vaccines in development might take an alternative route. Because of the public health emergency status, the FDA has the authority to authorize vaccines for use among the general public before it’s formally approved under an EUA.

Making that choice would be unprecedented. It would mean that the vaccine becomes available for general use without the rigorous review process. Additionally, the FDA could even elect to not publish the data that they considered for their EUA review.

Fortunately, in a joint letter signed this morning, the manufacturers of the vaccines currently under development have agreed to complete Phase III trials before applying to the FDA. However, the statement doesn’t commit to seeking full approval of the vaccine leaving emergency use authorization on that table. Such a move would short-circuit the FDAs data review and approval vetting process.

The joint letter signed by AstraZeneca, BioNTech, GlaxoSmithKline, Johnson & Johnson, Merck & Co., Moderna., Novavax., Pfizer and Sanofi. pledges to:

  • Always make the safety and well-being of vaccinated individuals our top priority.

  • Continue to adhere to high scientific and ethical standards regarding the conduct of clinical trials and the rigor of manufacturing processes.

  • Only submit for approval or emergency use authorization after demonstrating safety and efficacy through a Phase 3 clinical study that is designed and conducted to meet requirements of expert regulatory authorities such as FDA.

  • Work to ensure a sufficient supply and range of vaccine options, including those suitable for global access.

Editorial Note I: Waiting for the normal review process and official approval before distributing the vaccine to the general public would take an additional 6 to 8 weeks. During that time, the review team would have time to analyze the data and determine whether the vaccine is safe and effective and in what doses and to determine whether there are any sub-populations who may have adverse effects.

However, there will be intense pressure in some circles for the FDA to issue an EUA rather than the full licensing review. That may work out in the end, bit it might not.  And with several vaccines in the pipeline, even if the first one doesn’t work or had adverse effect there will be several others right behind it.

If a vaccine is distributed under an EUA and it doesn’t work out and there are bad adverse effects or if it’s ineffective but distributed anyway, it could do serious and lasting damage the overall confidence that vaccines are safe and effective- and that could have longer-lasting deleterious effects to public health.  Something to think about as we approach the end of the Phase III trials.

Editorial Note II: The Association for State and Territorial Health Officials (ASTHO) put out a clear statement urging the FDA to complete Phase III trials before making a decision either through an EUA or via Approval to release COVID-19 vaccine to the public. Here is an excerpt from their statement last week: 

“Our nation’s health officials are concerned by recent statements from FDA Commissioner Hahn and NIAID Director Fauci indicating they would consider authorizing the use of a COVID-19 vaccine prior to the completion of phase 3 clinical trials. The safety and efficacy of vaccines is paramount to protecting the health of the American public and to building confidence in our state and territorial immunization programs.

 “The nation’s health officials strongly encourage FDA to require the completion of phase 3 trials—or an equally rigorous evaluation—prior to approving a COVID-19 vaccine. Leadership must use the best available science to guide vaccine distribution decisions and timelines.”

 “We must also address concerning racial and ethnic inequities in vaccination rates and speak to the mistrust that many Americans have of governmental immunization efforts. Vaccinations are a monumental public health accomplishment built on decades of research and transparency by the world’s scientists. We must work together to ensure the COVID-19 vaccine builds upon this legacy.”

Dr. Gerald’s Latest Analysis of AZ’s COVID Trajectory

You can check out Dr. Gerald’s latest COVID Epidemiological Review Here. The Appendix this week has an informative county by county epidemiological analysis. Summary of Dr. Gerald’s report is below, but make sure to view the full report– there are lots of interesting figures in the report this week.

• Arizona is transitioning to a new phase of the outbreak where viral transmission is declining in the working-age and older adult populations but beginning to increase among adolescents and young adults. This is most likely attributable to re-opening of university campuses.

o Rising cases on university campuses pose an unknown risk to the broader community as it is unclear to what extent that the social networks of students and the broader community overlap.

o While the risk of severe disease in young adults is low, that is not the same as no risk. As case counts increase, some young adults will invariably require hospitalization and it is not out-of-the question that a small number of deaths could result.

o Reporting lag for PCR results has improved such that ≥90% of results are returned within 48 hours; however, the rapid rise in antigen testing on University campuses may present new challenges in data reporting and interpretation.

• Outside of young adults, levels of community-driven viral transmission remain comparatively high but continue to decline. Overall, transmission levels are on par with those observed in late-May.

o For all locales, mask-wearing ordinances will be needed for the foreseeable future to mitigate the spread of Covid-19.

o As some additional business activities (e.g., schools and businesses) resume, they will bring more people into closer contact and will facilitate additional viral transmission. Therefore, continued adherence with mask wearing, physical distancing, hand hygiene, and surface decontamination will be needed to mitigate these risks.

• Covid-related hospital utilization continues to decline while excess capacity is not being replenished owing to larger amounts of non-Covid care. However, adequate capacity is available for the foreseeable future.

o From now until January, non-Covid hospitalizations are expected to increase putting additional strain on hospital capacity.

o Hospitals will continue to experience large volumes of elective care to address the backlog of patients waiting elective procedures.

• Current Covid-19 test capacity appears adequate as evidenced by quick turn-around for PCR results and a PCR test positive percentage of 5% which is within the recommended 3 – 5% threshold.

o As more Covid-19 testing transitions to antigen testing, it is unclear how this might impact test positivity trends. A rising test positive percentage should raise the possibility of resurgence.

County Data (weekly crude and population-adjusted cases counts) appear in Appendix.

Next update scheduled for September 11.

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If somebody forwards this Weekly Public Health Policy Update to you & you’re interested in getting them every week – please join AzPHA!

You can join us at on our membership web linkIndividual memberships are only $75/year and student memberships priced at just $25/year

We also have various Organizational Memberships.

Diagnosing and Treating Pediatric Feeding Disorder Takes a Big Step Forward

One of our partners called Feeding Matters has been working for a few years to get pediatric feeding disorders a diagnostic code. Last week they we received word that CDC has officially approved Pediatric Feeding Disorder as a diagnostic code to the next edition of the International Classification of Disease (ICD) on October 1, 2021.

In just 5 short years, Feeding Matters has become the catalyst to the stand-alone definition and diagnosis of PFD.  This is huge news for our organization and a game changer for our work because, once the ICD code becomes active, clinicians will have a pathway for reimbursement from health insurance companies for treating PFD and more families will benefit from that treatment. 

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Join Us!

If somebody forwards this Weekly Public Health Policy Update to you & you’re interested in getting them every week – please join AzPHA!

You can join us at on our membership web linkIndividual memberships are only $75/year and student memberships priced at just $25/year

We also have various Organizational Memberships.

CMS Issues New Rules Strengthen COVID-19 Surveillance through Required Testing

CMS announced regulatory changes that require nursing homes to test staff and offer testing to residents for COVID-19. Laboratories and nursing homes using point-of-care testing devices will now be required to report diagnostic test results. The new rules also require hospitals to provide COVID-19 cases and related data to HHS.

This is a welcome intervention that will help save lives and protect valuable hospital capacity this fall and winter. It only applies to skilled nursing facilities that are certified by CMS (because Medicaid or Medicare is a payer for some of the residents). It wont help with Assisted Living centers or homes because those aren’t CMS certified.

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Join Us!

If somebody forwards this Weekly Public Health Policy Update to you & you’re interested in getting them every week – please join AzPHA!

You can join us at on our membership web linkIndividual memberships are only $75/year and student memberships priced at just $25/year

We also have various Organizational Memberships.

COVID19 & the Immune System

Part II: What About the Long Run, Is there Lasting Immunity?

Once the immune system is successful at fighting off a threat like the SARS CoV2 virus it can begin to relax.  Because the antigen is no longer around after a person finally recovers, there’s no need to continue to mount the immune response. The immune system keeps some antibodies around for a while just in case the person is exposed to the virus again. If that does happen, then the antibodies (IgG), are at the ready and can neutralize the virus right away and draw in a few phagocytes to kill the virus before it replicates.

After a couple of years have passed and the body hasn’t seen the virus around, it often begins to stop making those antibodies. But it has a memory.  Even if all the antibodies are gone from the blood, the immune system will remember that virus- even decades later in some cases. 

The B Cells that make the antibodies stand at the ready to make new antibodies right away and they won’t have the learning curve like they had the first time. Likewise, the T cells that specialized in attaching the virus will be at the ready.  Even when those original B and T cells eventually die- their offspring still remember the old virus and can ramp up fast.

Will People that Recover have Lasting Immunity? All indications are yes. An article recently published in the highly respected journal Nature found that patients who had recovered from COVID-19 mounted a full immune response that included the production of antibodies (via B cells), complement fixing, while blood cell production (phagocytes) and a robust T cell response.

This is an important finding that informs whether people that have recovered from a COVID-19 infection are protected from additional infections. The data in this study strongly suggest that the answer to that question is “yes, there is lasting immunity”.

Indeed, even after antibody production (titer) wanes after a period of months or years, the evidence suggests that memory B cells will be around to produce antibodies quickly if needed.  In addition, the study shows that specific T cells with memory will also be around to mount a specific response to a future exposure to the virus.

A separate study published in the British Medical Journal found that “recovered individuals developed SARS-CoV-2-specific IgG antibody and neutralizing plasma, as well as virus-specific memory B and T cells that not only persisted, but in some cases increased numerically over three months following symptom onset.  These findings demonstrate that mild COVID-19 elicits memory lymphocytes that persist and display functional hallmarks associated with antiviral protective immunity.”

COVID-19 & the Immune System

Part I – Antibodies, Leukocytes & T Cells

Over the last several months we’ve learned a lot about the nature of the immune response when someone is sick with and then recovers from a SARS CoV2 infection. At first, it was unclear whether and for how long immunity might last after recovery. Most of the public and media discussion has been about the lasting effect of neutralizing antibodies following recovery from COVID-19….  but the immune system is so much more than just an antibody response.

This week I’m doing my best to explain the basics of the immune system, how it works and it’s different components.

What Is the Immune System?

The immune system is the body’s defense against infections from pathogens like bacteria and viruses. It consists of a combination of different kinds of cells that attack pathogens to keep us healthy. Our immune system can detect different kinds of disease agents and it’s really good at telling the difference between harmful and harmless or even beneficial organisms (e.g. viruses, bacteria, and parasites).  It can tell the difference between the body’s own healthy cells or tissues, and ‘foreign’ cells.

When the immune system recognizes a pathogen (let’s take the SARS CoV2 virus as an example) it activates the immune system to protect the host. That immune response starts with intelligence gathering.

Intelligence Gathering

The immune system’s “intelligence gatherers” are called B lymphocytes.  You might also know them as Bursa cells. These cells go around the body all the time and look for foreign objects that could be harmful. They’re looking for “antigens” or proteins that look strange and potentially harmful.

For example, the SARS CoV2 virus that causes COVID-19 has a has a protein coat that is unique to that virus. The antigens, or protein coat spikes are those sharp looking things that are often depicted in the media when they show the virus. The immune system’s B cells brush up against the virus and gather intelligence- and when they see the SARS CoV2 virus, they immediately think uh-oh.  This is not good. Let’s make some antibodies to fight this antigen.

Emergency Response

Those antibodies are the “first responders” of the immune system. You can think of antibodies as firefighters that rush in to fight the threat that the invading virus may be posing. The B lymphocytes (B Cells) make the antibodies (also called immunoglobulins).  They are proteins that lock onto the specific antigen that’s the threat. 

You can think of it like a lock and key. The key needs to fit the lock to open the door. It’s like that, the antibody needs to fit the antigen to work too. When the key and the lock fit- the harmful virus becomes neutralized. Not dead, but neutralized.

There are several different kinds of antibodies. Two of the most important at IgM and IgG. Both are antibodies, but they have slightly different purposes. The IgM antibodies produced by the B cells form first, within the first couple days after infection. They do an OK job, but they aren’t super effective- but they can be made really fast. IgG antibodies take longer to make but do a better job once they get there.

Antibodies lock on to the threat and neutralize it, but they can’t kill the virus without help. The antibodies put handcuffs on the virus so that it’s held in abeyance until assistance arrives.  The first help to arrive is a group of proteins called “complement”.

The complement arrives and sees that an antibody has locked on to the SARS virus.  Complement triggers a chemical reaction that damages or kills the viruses, infected cells and other close by cells that are healthy. The complement is a pretty blunt immune system instrument because it kills both the virus, infected cells and other cells that aren’t infected. 

But more help is on the way.  They’re called “phagocytes”.

Calling in the Cavalry

Phagocytes are immune system cells that “eat” harmful foreign particles, bacteria, as well as dead or dying cells. These cells come to the rescue when they see that antibodies have been neutralizing harmful pathogens and causing a complement response. These “professional” phagocytes include a host of different white blood cells called neutrophils, monocytes, macrophages and dendritic cells.

These cells act to kill the invading organism, but it comes at a cost, because healthy host bystander cells are destroyed as the phagocytes react to the threat.  The macrophages and neutrophils for example cause an inflammatory response that damages healthy host tissue. They destroy pathogens by engulfing them and subjecting them to toxic chemicals. 

Sometimes those toxic chemicals are released into the environment causing the damage to healthy host cells. This process helps the body get rid of the harmful invaders but also causes inflammation to normal healthy cells that are bystanders.

Bringing in the Specialists

The immune system specialists are the T Cells.  They provide an important role in controlling and shaping the overall long-term immune response.  They use signaling proteins called cytokines to recruit to mount an immune response. Other kinds of T cells are called “helper cells” which indirectly kill foreign cells by attracting phagocytes.

The T cells learn to specifically target the harmful invaders and can attack those invading virus and bacteria in a targeted way that causes less collateral damage to the surrounding tissue. They can also recognize, target, and destroy things like cancer cells. 

People spend their whole career studying T cells and their function in the immune system- so their work is complex and important.

Part II Tomorrow: Is there Lasting Immunity Post Infection?

National Academy Releases Initial Plan for the Equitable Allocation of Vaccine

Comment Period Ends Next Friday: We Need to Focus Next Week & Get Comments in to Ensure Health Equity is Included

With the Phase II vaccination clinical trials showing promising results and Phase III trials well underway, it’s time to develop a comprehensive state plan for the equitable prioritization and deployment of COVID-19 vaccine in Arizona. The plan will need to set priorities for the early doses as well as outline the logistical details of its distribution. Fortunately, there is a new national report that can help Arizona officials think through Arizona’s priority populations.

The National Academies of Medicine just published that report which is entitled Preliminary Framework for the Equitable Allocation of COVID-19 Vaccine. The report part is part of a study commissioned by the NIH and CDC. The Guiding Principles that the team used is on Page 15 and the priority populations are outlined starting on page 22. The proposed Tier 1 populations include:

  • Front-line healthcare workers

  • Emergency services workers

  • Public health workers

  • Vaccine manufacturers

  • Immunization teams

  • Persons with high-risk conditions (e.g. seniors)

  • Long-term care workers

  • Persons performing core societal functions (e.g. front-line public transit, food supply, schools)

The report doesn’t provide any guidance for sub-prioritization of Tier 1 populations. Sub-prioritization of Tier 1 populations will be necessary in a final report or in any state plan, as there will not be adequate vaccine at the beginning for all of the Tier 1 populations.

A public listening session will be held tomorrow (Sept. 2) from 9 a.m – 2 p.m. AZ Time. The listening session requires registration. More information about the public comment period is available here.

The initial written comment period will ONLY be open from Sept. 1-4 so we will need to work quickly next week to get our comments in. Hopefully many of our members can listen in and develop thoughts about the initial plan- with a lens to ensuring it includes health equity. Let’s post those comments on our policy committee Basecamp this upcoming week so we can get comments in by Friday.

https://www.nationalacademies.org/VaccineAllocationComment

Bars Open Across Arizona

Bars have now opened across almost all of Arizona. There are just a few counties that haven’t yet met the moderate spread metrics- and over 90% of Arizonans now live in counties where bars are open. In order to open, bars are supposed to go to the ADHS website and attest that they will follow mitigation measures.

Following mitigation measures is critical in these businesses. As we saw between May 15 and June 26 bars and nightclubs create super-spreading environments without mitigation.

Over the last couple of weeks there has been some strong administrative advocacy urging the state to develop a meaningful compliance program to ensure that bars and nightclubs follow the required mitigation measures upon opening. ADHS had already been requiring bars and nightclubs to sign attestations that they’ll follow mitigation measures, but until late last week there wasn’t an organized active compliance system.

The advocacy worked and late last week the department announced that they would be sponsoring a COVID-19 Compliance Hotline at 1-844-410-2157.  They committed to investigating complaints by referring them to the county health departments or in some cases investigating the complaints themselves.

Editorial Note: Let’s hope that the plan is well organized and works. If the compliance program isn’t effective, we can expect broad non-compliance with mitigation as we say earlier this summer, creating an increase in cases. If that happens, students in the K-12 system will suffer if that happens because counties would no longer meet in person instruction benchmarks in short order. That lost opportunity would be directly attributable the lack of an effective compliance system for bars and nightclubs.