August 16, 2005

Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-3198-P,
P.O. Box 8010,
Baltimore, MD 21244-8010
Dear Sir or Madam;

Reference: file code CMS-3198-P

Issues: 1. General and 2. BACKGROUND

Issue 1: General:
Two main problems suggest themselves with a program to withhold government finances based on compliance with 'Flu Immunization.'

1. Using government tax money to coercively sell a product.
2. Basing policy on Pharmaceutical company propaganda and financial recommendations rather than the real science which is available to the CDC.

Issue: General:

First: our nursing homes today are filled with the generation of individuals which lived through WWII. These people made heroic sacrifices to keep our country free and now they find themselves in need of care givers who are being forced to offer and even coerce the acceptance of a product which has been thoroughly disproven in effectiveness and is clearly more dangerous than the malady which the product is falsely alleged to prevent.

Issue: BACKGROUND:
Secondly: Over the past 25 plus years the combined rate of pneumonia and influenza related deaths has risen in the over 65 population while at the same time the number of flu vaccinations has doubled in this age group. This data effectively makes a long term, large population group study which clearly proves the flu vaccine is not only a failure but very likely is making an actual contribution to the problem, not the solution. The CDC and CMS should reject manufacturers' claims and begin using basic information that is scientifically sound for the purpose of creating national policy.

The article, Prevention and Control of Influenza, Recommendations of the Advisory Committee on Immunization Practices (ACIP) found at http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5306a1.htm is used as a justification for the proposed policy under discussion. This proposed policy ignores the fact that the vaccine trials are conducted by vaccine manufacturers who have a record of twisting the truth, the trials are not independently supervised, the word "Placebo" is mentioned several times but in NO vaccine trial is a proper placebo (harmless inactive substance) ever used thus making the methodology of the trials flawed. In addition, data on how the subjects are randomized is not given, leading one to suspect that the placebo is given by area and not by a proper one-by-one randomization. All these biasing factors make the claimed figures for effectiveness meaningless.

In addition, the ACIP is itself fraught with conflicts of interest and must be regarded as nothing more than a vaccine promotion group which makes financial recommendations but never valid scientific recommendations.

Certain figures quoted under the issue, BACKGROUND, are clearly misleading. We are told that "... epidemics of influenza have been responsible for an average of approximately 36,000 deaths per year in the United States between 1990 and 1999." In fact, the figure of 36,000 is the number of combined flu and pneumonia related deaths. Less than 10% of these deaths are flu related. For children under 5, only about a half of one percent (.5%) of the 36,000 are due to flu. In other words, the deaths related to flu in the under 5 group are about 1 per 100,000 of the age group. The flu vaccine itself can easily kill more than 1 in 100,000, and even more among infants, plus raise the rate of deaths from Influenza Like Illnesses in addition to the direct deaths caused by the vaccine. Recent estimates for the USA place the over 65 population at nearly 36.7 million. If, for a convenient estimate, we put flu deaths in this age group at 3670 (about 10 percent of the 36,000 advertised) then we have flu deaths at 1 per 10,000 in the over 65 population. Vaccinating 36.7 million over 65 individuals, including the most immunocompromised of our population, is a harmful policy which the last 25 years of flu vaccine usage and the accompanying increase in combined flu and pneumonia deaths proves to be an ineffective procedure.

Both legislative mandates and financially coerced vaccination policies are ideas whose time is past. Discontinuing such policies is the choice of informed, free thinking, health achieving and progressive minded persons.

Sincerely yours,

______________

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2005-08-16T16:36:55