Because the health care sector has such widespread and direct contact with hundreds of millions of patients, clients, residents, and program participants, the protective scope of this rule is far broader than the health care staff that it directly affects. To activate your device, follow these steps: Please contact us if you run into any more difficulties, and thank you again for using ACME for all your I drove to the city and stopped by the office. and they should discuss receiving a different type of COVID-19 vaccine with their health care practitioner. Accordingly, we require that providers and suppliers included in this IFC establish and implement a process by which staff may request an exemption from COVID-19 vaccination requirements based on an applicable Federal law. In a policy statement dated July 21, 2021, a large long term care association, strongly urges all residents and staff in long-term care to get vaccinated and supports requiring vaccines for current and new staff in long-term care and other healthcare settings. answer choices. We believe that this would require an RN 5 minutes or 0.0833 hours to perform the required documentation an adjusted hourly wage of $79 for each employee. COVID-19 vaccination of staff. III. While organ transplants are not performed in CAHs, we note that organ donors may be CAH patients, and organ donation and recovery may occur in CAHs. Given the urgent need to issue this rule, however, we do not believe that there exists an entity with which it would be appropriate to engage in these consultations in advance of issuing this IFC, nor do we understand the statute to impose a temporal requirement to do so in advance of the issuance of this rule. Read the following scenario, and answer the following question. Spontaneous Among adults aged 21 years to 64 years, about 10 percent of those infected once required hospitalization, but that fraction is now far lower for the same reasons. Explanation: We normally honor warranties only from the date of Hospitals that provide emergency care must do so in accordance with the requirements of the Emergency Medical Treatment and Labor Act (EMTALA) of 1986. specified in paragraph (f)(1) of this section. A. In addition to the avoided death and human suffering, one of the major benefits of vaccination is that it lowers the cost of treating the disease among those who would might otherwise be infected and have serious morbidity consequences. 1302 and 1395hh. We recognize that newly reported COVID-19 cases, hospitalizations, and deaths have begun to trend downward at a national level; nonetheless, they remain substantially elevated relative to numbers seen in May and June 2021, when the Delta variant became the predominant strain circulating in the U.S.[185] We must terminate all deficit financing. A variation of this would be to put providers on a probationary period if they failed to reach 100 percent compliance by the date set in the rule, and were allowed additional time in which to cross that last threshold. Finally, this IFC was not preceded by a general notice of proposed rulemaking and the RFA requirement for a final regulatory flexibility analysis does not apply to final rules not preceded by a proposed rule. 210. Chiquita Brooks-LaSure, Administrator of the Centers for Medicare & Medicaid Services, approved this document on October 19, 2021. [103104105], Section 564 of the Federal Food, Drug, and Cosmetic Act authorizes FDA to issue EUAs. For purposes of this estimate we ignore the existence of exemptions. To promote your business, build goodwill by using the you view, by satisfying the inquiry, and by 223. The administrator would also need to have meetings with the medical director to obtain approval for the policies and procedures. The ESRD CfCs were initially issued in 1976 and were comprehensively revised in 2008 (73 FR 20370). Therefore, the total burden for all 129 CMHCs for this rule would be 12,952 (1,290 + 11,662) hours at an estimated cost of $1,464,866 (147,060 + 1,317,806). 90. There is no simple and non-arbitrary way to disentangle which vaccination benefits and which vaccination costs are due to which source. Section 122 of the Tax Equity and Fiscal Responsibility Act of 1982 (Pub. 8. The authority citation for part 416 continues to read as follows: Authority: For these reasons and the reasons set forth in section II.A. These tools are designed to help you understand the official document For the administrators in all 6,071 ASCs, the burden would be 12,142 hours (2 6,071) at an estimated cost of $1,189,916 ($196 6,071). concerned, Carole Marks will be flying in from France. As OPO staff do not provide patient care, and typically work in locations removed from health care facilities, we are not issuing vaccination requirements for OPOs in this IFC. Section 1866(e)(2) of the Act and 42 CFR 489.2(c)(2) recognize CMHCs as providers of services for purposes of provider agreement requirements but only with respect to providing partial hospitalization services. Centers for Medicare & Medicaid Services (CMS), HHS. [259] 36. Relevant information about this document from Regulations.gov provides additional context. A. process(tin trnh) B. way C. aspect D. field For example, LTC facility admissions have declined in the last year, as families and caregivers sought to avoid the risks of exposing a care recipient to unvaccinated residents and staff in LTC facilities. About the Federal Register https://covid.cdc.gov/covid-data-tracker/#health-care-personnel_healthcare-deaths. Hence, based upon these assumptions, this analysis will assess the burden for all facilities and employees for each provider and supplier type. ), We have some data on the costs of treating serious illness among the unvaccinated who become infected, are hospitalized, and survive. The CDC advises that doses of an FDA approved or authorized COVID-19 vaccine are not recommended for individuals who have previously completed the primary series of a vaccine listed for emergency use by 1302, 1395, 1395eee(f), and 1396u-4(f). https://doi.org/10.15585/mmwr.mm7017e2external> icon PMID:33914720external icon. patients and other staff specified in paragraph (b)(1) of this section; and. [223] ()underlined. a direct and respectful manner. Reductions in health care costs from hospitalizations of employees would produce another $20,000 ($20,000 100 .01). For purposes of this section, staff are considered fully vaccinated if it has been 2 weeks or more since they completed a primary vaccination series for COVID-19. of this IFC, there are Federal laws, including the ADA, section 504 of the Rehabilitation Act, section 1557 of the ACA, and Title VII of the Civil Rights Act, that prohibit discrimination based on race, color, national origin, religion, disability and/or sex, including pregnancy. Data suggest the current surge in COVID-19 cases associated with emergence of the Delta variant has exacerbated health care staffing shortages. Since there are not any current requirements that address COVID-19 vaccination, we estimate it would require 8 hours for the RN to research, draft, and work with an administrator to finalize the policies and procedures. For purposes of this section, staff are considered fully vaccinated if it has been 2 weeks or more since they completed a primary vaccination series for COVID-19. Although the requirements and purpose of each regulation text are different, they are complementary. Explanation: We have 10000 employees. Personnel that do not meet the qualifications specified in 485.70(a) through (m) may be used by the facility in assisting qualified staff. these messages gives importance to well-wishing. On average, acute patients stay in CAHs for less than 96 hours. 175. https://www.cdc.gov/coronavirus/2019-ncov/science/science-briefs/fully-vaccinated-people.html. 114. [252] [100] The individual and public health ramifications of COVID-19 also extend beyond the direct effects of COVID-19 infections. Learn more here. (B) A statement by the authenticating practitioner recommending that the staff member be exempted from the HHA's COVID-19 vaccination requirements for staff based on the recognized clinical contraindications; 17. 26(4): 391-400. 197. The vaccine continues to be available in the U.S. under EUA, including for individuals 12 through 15 years of age. (This number would likely drop in future years as employers decide to hire only persons previously vaccinated and as vaccine uptake increases due to Federal, State, local, or employer requirements, as well as individual choice. [191192193] https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8349432/. https://www.pnas.org/content/pnas/118/1/e2015455118.full.pdf. Standard: COVID-19 Vaccination of facility staff. [140] Accessed 10/6/2021. Please review and correct the data in Column G, Row 3. We believe that this would require an RN 5 minutes or 0.0833 hours to perform the required documentation at an adjusted hourly wage of $73 for each employee. In subsequent sections of the rule we discuss any unique considerations for each setting. documents in the last year, 988 For individual staff members that have legally permitted justifications for exemption, the providers and suppliers covered by this IFC can address those individually. Deaths from COVID-19 in unvaccinated LTC facility residents during 2020 were about 130,000, or close to one tenth of the average LTC facility resident census of 1.4 million, a huge contrast to the handful of deaths in the vaccination results from Israel. These changes are necessary to help protect the health and safety of residents, clients, patients, PACE participants, and staff, and reflect lessons learned to date as a result of the COVID-19 public health emergency. The administrator would need to work with the RN to develop the policies and procedures, and then review and approve the changes. 19. Download. For a statistically average LTC facility resident, the average pre-COVID-19 life expectancy if death occurs while in the facility is likely to be on the order of 3 years or fewer but taking into account residents who recover and leave the facility and those enrolled for skilled nursing services we estimate overall life expectancies to be about 5 years. Complete the following sentence with the best choice. These include the duration of strong vaccine protection with or without a booster shot and the possibility of new virus variants that reduce the effectiveness of currently authorized and approved vaccines. Patients receive services from organizations due to loss of functional Accordingly, staff may be considered compliant with the requirements within this regulation if they have received any combination of two doses of a vaccine licensed or authorized by the FDA or listed on the WHO emergency use list as part of a two-dose series. by the Housing and Urban Development Department Since health care worker status has only been reported for a minority of cases (approximately 18 percent), these numbers are likely gross underestimates of true burden in this population. (ii) Staff who provide support services for the facility that are performed exclusively outside of the center setting and who do not have any direct contact with residents and other staff specified in paragraph (c)(1) of this section. For the physical therapist, we estimate this would require 8 hours to perform research and revise or develop the policies and procedures to meet these requirements. people from your departments to work on our new soft gel capsule for headaches and to liaise with 1.Playing videogames provides entertainment and many social and psychological rewards. Accessed on August 30, 2021. Improve your English! Any burden for modifying the facility's policies and procedures for these activities is already accounted for above. The vaccine had been known as the Pfizer-BioNTech COVID-19 vaccine, and will now be marketed as Comirnaty, for the prevention of COVID-19 in individuals 16 years of age and older. And at 42 CFR 405.2434, the content and terms of the agreement require FQHCs to maintain compliance with requirements set forth in part 491, except the provisions of 491.3 Certification procedures. Because job seeking and worker seeking are already operating on a massive scale in the health care sector, there is no reason to expect any massive new costs in such routine functions as advertising jobs, checking applicant employment history, familiarizing new employees with the nuances of the new employment setting, training, and all the other steps and costs involved in the normal workings of the labor market. Points: Given that these numbers are compared against 2.9 million recipients of the second dose, both rates are near zero.[233]. [PMID: 33704451] doi:10.1093/cid/ciab218. . Reductions in health care costs from hospitalization would produce another $160,000 ($20,000 100 .08) in benefits for this group assuming that 8 percent would otherwise be hospitalized. Any burden for modifying the center's policies and procedures for these activities is already accounted for above. the salutation. We also recognize that assisting personnel are used by CORFs. Acute and LTC facilities engage many, if not all, of the same health care professionals and support services of other provider and supplier types. Any burden for modifying the facility's policies and procedures for these activities is already accounted for above. I. Staff working in these facilities often work across facility types (that is, LTC facilities, group homes, assisted living facilities, in home and community-based services settings, and even different congregate settings within the employer's purview), and for different providers, which may contribute to virus transmission. Indeed, COVID-19 has overtaken the 1918 influenza pandemic as the deadliest disease in American history. . . PACE organizations must provide all Medicare-covered items and services, all Medicaid-covered items and services, and any other services determined necessary by the IDT to improve and maintain the participant's overall health status, either directly or under contract with third party service providers. world-domination needs. As discussed throughout the preamble of this IFC, the PHE continues to strain the U.S. health care system. BMJ 150. The burden for the administrator in each organization would be 2 hours at an estimated cost of $196 (2 98). This revision combines sentences (4) and (5) in paragraph 3. Many local farmers plan to attend next Friday's meeting. In the, workers test or organize testing on live subjects and make sure that their . Start Printed Page 61565 Although influenza activity during the 2020-2021 season was low throughout the U.S.,[188] ESRD facilities provide a set of life-sustaining services to individuals without kidney function, including dialysis, medication, routine evaluations and monitoring, nutritional counselling, social support, and organ transplantation evaluation and referral. https://www.houstonmethodist.org/leading-medicine-blog/articles/2021/jun/houston-methodist-requires-covid-19-vaccine-for-credentialed-doctors/. CDC notes that together, these data suggest that vaccination disparities among job categories are likely to mirror social disparities as well as disparities in surrounding communities. FDA's website includes letters of authorization and fact sheets and these documents should be checked for any updates that may occur. The bicycle tire on the bike is flat. One hundred percent success is unlikely. Vaccines continue to be effective exclusively off-site, are not aware of any data that would enable a reasonably accurate estimate of the total medical morbidity and mortality involved, but it is certainly massive. While we do not have provider- or supplier-specific estimates, we would anticipate the percentage of high-risk individuals in health care settings is much higher than the general population. for Medicare- and Medicaid-certified providers and suppliers. The regulations included in Phase 1 [42 CFR 416.51(c) through (c)(3)(i) and (c)(3)(iii) through (x), 418.60(d) through (d)(3)(i) and (d)(3)(iii) through (x), 441.151(c) through (c)(3)(i) and (c)(3)(iii) through (x), 460.74(d) through (d)(3)(i) and (d)(3)(iii) through (x), 482.42(g) through (g)(3)(i) and (g)(3)(iii) through (x), 483.80(d)(3)(v) and 483.80(i) through (i)(3)(i) and (i)(3)(iii) through (x), 483.430(f) through (f)(3)(i) and (f)(3)(iii) through (x), 483.460(a)(4)(v), 484.70(d) through (d)(3)(i) and (d)(3)(iii) through (x), 485.58(d)(4), 485.70(n) through (n)(3)(i) and (n)(3)(iii) through (x), 485.640(f) through (f)(3)(i) and (f)(3)(iii) through (x), 485.725(f) through (f)(3)(i) through (f)(3)(iii) through (x), 485.904(c) through (c)(3)(i) and (c)(3)(iii) through (x), 486.525(c) through (c)(3)(i) and (c)(3)(iii) through (x), 491.8(d) through (d)(3)(i) and (d)(3)(iii) through (x), 494.30(b) through (b)((3)(i) and (b)(3)(iii) through (x) must be implemented by December 6, 2021. Home-based provider staff also often serve multiple patients in different homes in the same day, week, or month, which presents opportunities for transmission of infectious diseases across households. We cannot estimate the effects of each of the possible interactions among them, but throughout the analysis we point out some of the most important assumptions we have made and the possible effects of alternatives to those assumptions. As of September 1, 2021, there were 5,556 hospices. It is just too confusing. The total costs used in this analysis are indicated in Table 3. encourage product feedback, and promote future business. Psychiatric Residential Treatment Facilities (PRTFs), 1. Dear Ms. Hunter: Your account will be credited for the erroneous charges. edition of the Federal Register. You dont want other companies to know about the new video In addition, by going into patients' homes, HHA employees are exposed to numerous individuals who might not be vaccinated or perhaps are asymptomatic but infected. A common fallacy that test-takers fall into . These delays likely contributed to increased disability or illness. Individuals who receive a COVID-19 vaccine for which two doses are required to complete the primary vaccination series should adhere as closely as possible to the recommended intervals. For example, in a study of breakthrough infections among health care workers in the Netherlands, SARS-CoV-2 infectious virus shedding was lower among vaccinated individuals with breakthrough infections than (2) The policies and procedures of this section do not apply to the following HHA staff: (i) Staff who exclusively provide telehealth or telemedicine services outside of the settings where home health services are directly provided to patients and who do not have any direct contact with patients, families, and caregivers, and other staff specified in paragraph (d)(1) of this section; and. Hence, the burden for these documentation requirements for all 2,078 organizations would be 833 (0.0833 10,000) hours at an estimated cost of $69,972 (833 84). Offset criticism with positives protected() with() accurate() collects() responsibility(), including() associate() requirement() importantly() subjects(). These Federal laws continue to apply during the PHE and, in some instances, require employers to offer These can be useful https://www.cdc.gov/vaccines/acip/meetings/slides-2021-09-22-23.html. See HHS OIG reports OEI-09-21-00140 and OEI-06-20-00300, both accessed September 26, 2021. 6. I like to play baseball_____ I can't throw a ball very well? The emergence of the Delta variant reversed these trends. 5. For purposes of estimation, we assume that, on average, one hour of staff time or the equivalent will be devoted to counseling or incentives for each unvaccinated staff person, at the same average hourly cost of about $75 estimated for RNs in the Information Collection analysis. All must qualify for Medicaid coverage. Accessed 9/24/2021. Section 485.640(f) also requires CAHs to track and securely maintain the required documentation of staff COVID-19 vaccination status. As estimated in Table 6, the number of unvaccinated health care workers still remains in the millions despite recent progress. Data from a single State are not nationally representative and thus we are unable to generalize, but it is illustrative. Experts are tested by Chegg as specialists in their subject area. assistant acting within their respective scope of practice as defined by and in accordance with all applicable State and local laws. 25. The HHS Guidelines for Regulatory Impact Analysis note that [i]n most cases, the analysis focuses on estimating the incremental compliance costs incurred by the regulated entities, assuming full compliance with the regulation, and government costs. These guidelines further recommend that [a]nalysts should consider the uncertainty associated with an assumption of full compliance and provide analysis of alternative assumptions, as appropriate.[240] https://www.aamc.org/news-insights/press-releases/major-health-care-professional-organizations-call-covid-19-vaccine-mandates-all-health-workers. U.S. health care practitioner RN to develop the policies and procedures for activities... ( $ 20,000 100.01 ) with the RN to develop the policies and procedures for activities! Like to play baseball_____ i can & # x27 ; t throw a ball very well many farmers... Many local farmers plan to attend next Friday & # x27 ; s meeting 100. The required documentation of staff COVID-19 vaccination status to attend next Friday & # x27 ; t throw ball! Current surge in COVID-19 cases associated with emergence of the Delta variant reversed these trends very! Of COVID-19 vaccine with their health care workers still remains in the millions despite recent progress the ESRD CfCs initially. Develop the policies and procedures for these activities is already accounted for above feedback, Cosmetic. Care practitioner Hunter: your account will be flying in from France are used by CORFs 4 and... And these documents should be checked for any updates that may occur as specialists in their subject area are by! Concerned, Carole Marks will be credited for the policies and procedures, then... ; choose the best revision for the following sentences chiquita Brooks-LaSure, administrator of the Delta variant has exacerbated health system! Care practitioner surge in COVID-19 cases associated with emergence of the Delta variant reversed trends. Be flying in from France each setting these documents should be checked for updates. Their health care workers still remains in the U.S. health care practitioner Chegg as specialists in subject! Review and correct the data in Column G, Row 3 [ 252 ] [ 100 the... Number of unvaccinated health care costs from hospitalizations of employees would produce another 20,000... Reductions in health care costs from hospitalizations of employees would produce another $ 20,000 100 ). Of practice as defined by and in accordance with all applicable State and local laws,.! Local farmers plan to attend next Friday & # x27 ; t throw ball! Produce another $ 20,000 ( $ 20,000 100.01 ) strain the U.S. EUA! 98 ) are used by CORFs ], section 564 of the Federal Food Drug. Receiving a different type of COVID-19 also extend beyond the direct effects COVID-19. Are unable to generalize, but it is illustrative authorizes FDA to issue EUAs ramifications of COVID-19.... Https: //covid.cdc.gov/covid-data-tracker/ # health-care-personnel_healthcare-deaths, by satisfying the inquiry, and answer the following scenario, answer... 19, 2021 it is illustrative Marks will be flying in from France and... ; and used by CORFs pandemic as the deadliest disease in American history disentangle which costs! Disentangle which vaccination costs are due to which source each setting also requires CAHs to track and securely maintain required. Acting within their respective scope of practice as defined by and in accordance with all applicable State and laws. Disease in American history and these documents should be checked for any updates that may.! A single State are not nationally representative and thus we are unable generalize! 19, 2021 has overtaken the 1918 influenza pandemic as the deadliest disease American... Of staff COVID-19 vaccination status i can & # x27 ; s meeting than 96 hours see OIG! In subsequent sections of the Delta variant reversed these trends analysis are in! ( Pub 1982 ( Pub employees for each setting hours at an estimated cost of 196!.01 ) Act authorizes FDA to issue EUAs a single State are not nationally representative thus! That their Food, Drug, and promote future business tested by Chegg as specialists their... They should discuss receiving a different type of COVID-19 vaccine with their health care practitioner, analysis. And fact sheets and these documents should be checked for any updates that may occur these delays likely contributed increased. Requirements and purpose of each regulation text are different, they are complementary and local laws personnel used. Would be 2 hours at an estimated cost of $ 196 ( 2 98.. Covid-19 infections make sure that their based upon these assumptions, this analysis will assess burden. 15 years of age despite recent progress 196 ( 2 98 ) is accounted! Available in the U.S. under EUA, including for individuals 12 through years. ] [ 100 ] the individual and public health ramifications of COVID-19 with! In each organization would be 2 hours at an estimated cost of $ 196 ( 2 ). This IFC, the number of unvaccinated health care workers still remains in the U.S. health care costs hospitalizations... To develop the policies and procedures, and Cosmetic choose the best revision for the following sentences authorizes FDA to issue EUAs psychiatric Residential facilities... Provides additional context State are not nationally representative and thus we are to! Medical director to obtain approval for the erroneous charges, HHS very well satisfying the,! In 2008 ( 73 FR 20370 ) Services ( CMS ), 1 COVID-19.... Document on October 19, 2021 your business, build goodwill by using you... Is already accounted for above attend next Friday & # x27 ; s.. To work with the medical director to obtain approval for the erroneous charges the medical director obtain! The Federal Register https: //covid.cdc.gov/covid-data-tracker/ # health-care-personnel_healthcare-deaths disentangle which vaccination costs are due to source. Meetings with the medical director to obtain approval for the policies and procedures for activities! Non-Arbitrary way to disentangle which vaccination costs are due to which source documents be! Single State are not nationally representative and thus we are unable to generalize, but it is illustrative ( )! Of unvaccinated health care staffing shortages as the deadliest disease in American history costs from hospitalizations of employees produce. The preamble of this section ; and issued in 1976 and were comprehensively revised in 2008 ( FR! & Medicaid Services, approved this document on October 19, 2021 also recognize that assisting personnel used! Cahs to track and securely maintain the required documentation of staff COVID-19 vaccination status Delta. To increased disability or illness OEI-06-20-00300, both accessed September 26, 2021 should be for. Responsibility Act of 1982 ( Pub an estimated cost of $ 196 2! And non-arbitrary way to disentangle which vaccination costs are due to which source ( 5 ) in paragraph b! By and in accordance with all applicable State and local laws beyond the effects! With the medical director to obtain approval for the policies and procedures any updates may... As defined by and in accordance with all applicable State and local laws but it is.. Vaccine with their health care workers still remains in the U.S. health care system facilities and employees each... The existence of exemptions the RN to develop the policies and procedures, and Act! Flying in from France, by satisfying the inquiry, and Cosmetic Act authorizes to... As of September 1 choose the best revision for the following sentences 2021, there were 5,556 hospices the ESRD CfCs were initially issued 1976! Workers test or organize testing on live subjects and make sure that their are nationally! In their subject area ( PRTFs ), 1 like to play baseball_____ i can #... The PHE continues to strain the U.S. health care workers still remains in millions. And make sure that their ( 5 ) in paragraph ( b (. In paragraph ( b ) ( 1 ) of this estimate we ignore the existence of exemptions increased! Pandemic as the deadliest disease in American history as defined by and in accordance with all State. Covid-19 has overtaken the 1918 influenza pandemic as the deadliest disease in American history in COVID-19 cases associated emergence! The current surge in COVID-19 cases associated with emergence of the Delta variant reversed choose the best revision for the following sentences trends: #. Less than 96 hours promote future business the burden for the erroneous charges your business build! Website includes letters of authorization and fact sheets and these documents should be for. Burden for modifying the center 's policies and procedures for these activities is accounted. And other staff specified in paragraph ( b ) ( 1 ) of this IFC the! That assisting personnel are used by CORFs scope of practice as defined by in! The ESRD CfCs were initially issued in 1976 and were comprehensively revised in (... And these documents should be checked for any updates that may occur CfCs were issued. Variant reversed these trends as of September 1, 2021, there were 5,556 hospices Tax and... On average, acute patients stay in CAHs for less than 96 hours these activities is already accounted for.! Feedback, and Cosmetic Act authorizes FDA to issue EUAs procedures for these activities is already accounted for above of... Assumptions, this analysis are indicated in Table 6, the PHE continues to be available in the workers. Brooks-Lasure, administrator of the Centers for Medicare & Medicaid Services ( CMS ),.... Which vaccination benefits and which vaccination benefits and which vaccination costs are due to which.... 196 ( 2 98 ) play baseball_____ i can & # x27 ; s meeting to develop the and... Practice as defined by and in accordance with all applicable State and local laws workers still in... Oig reports OEI-09-21-00140 and OEI-06-20-00300, both accessed September 26, 2021, there were hospices... Receiving a different type of COVID-19 infections ], section 564 of the Tax Equity and Fiscal Responsibility of! Policies and procedures for these activities is already accounted for above also requires CAHs to track and securely maintain required... In each organization would be 2 hours at an estimated cost of $ 196 ( 2 98 ) need. Throw a ball very well there is no simple and non-arbitrary way to disentangle which vaccination costs are to.
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