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DOH releases implementing guidelines for COVID-19 vaccination Priority Group A3 including PLHIV

The Department of Health a memorandum providing further guidance on COVID-19 vaccination of persons with comorbidities, including people with HIV. For Stephen Christian Quilacio of the Center for HIV and AIDS Responses (CARE), simplifying processes is needed, else this population will be excluded among the priorities.

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With the Philippine government ramping up its COVID-19 Vaccine Deployment Program that started on March 1 with the use of SinoVac and AstraZeneca vaccines, the Department of Health (DOH) issued Memorandum No. 2021-0099. Signed by Undersecretary of Health Dr. Ma. Rosario Vergeire, it eyes to “provide further guidance on implementation of simultaneous vaccination to priority groups, and implementing guidelines for Priority Group A3: adults with controlled comorbidities.”

This memo specifies how persons living with HIV (PLHIV) will be included in the vaccination program.

Stephen Christian Quilacio, who helms the Center for HIV and AIDS Responses (CARE), stated that “having these guidelines is good, though only to an extent. In the case of PLHIVs in particular, there’s this seeming constant addition of obstacles that hinder them from getting vaccinated, even if they are among ‘persons with comorbidities’.” And so for him, “simplify, simplify, simplify; provide the vaccines in treatment hubs/facilities.”

LGU-centric vaccination program

To start, the DOH Task Group Immunization Program, with the Department of Information and Communications Technology (DICT), mandates the establishment of “a platform for both electronic and manual masterlisting”, made available for “the entire population that is collected and used consistent with Data Privacy Law.”

Basically, therefore, registration is to be done through the local government units (LGUs), and not through the DOH or the treatment hubs/facilities – among others – for PLHIVs. With the handling of data collected, “the memo is – basically – optimistic that specifications in the Data Privacy Law will be followed,” said Quilacio, noting that “the likes of Human Rights Watch documented how disclosure remains an issue in the HIV community, with nothing being done to documented cases related to this.”

For Quilacio, “too many people are involved in data handling, increasing the risk of data leaks.”

Secondly, the memo stipulates that local government units (LGUs) are supposed to ensure vaccination of PLHIVs is “conducted or scheduled either in a separate site/facility stated below or in current LGU vaccination sites but at a separate date from the other populations”. This is to “keep privacy and confidentiality of patients.”

Related to the above, HIV treatment hubs/facilities may offer vaccination, though this is “provided that the treatment hubs have adequate human resource and capability to conduct the vaccination.”

Interviewed by Outrage Magazine, one HIV service provider who asked to remain anonymous said that they have actually already spoken with the LGU where their treatment facility is located. According to this service provider, they were informed that:

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  1. They still needed to be trained re COVID-19 vaccination;
  2. Their facility has to be inspected, and has to pass the stringent criteria of the LGU to become a vaccination site; and
  3. They are only to provide COVID-19 vaccines to PLHIVs serviced by the local social hygiene clinic.

The training and the accreditation could take time; but the latter part is “also extremely contentious,” said CARE’s Quilacio because many PLHIVs are clients of treatment hubs/facilities that are not in the same LGU where they live.

“For instance, a PLHIV may be a client of RITM in Alabang; but he/she may live in Tarlac; just as many PLHIVs in Davao del Sur are clients of Davao City’s treatment facility. Where do they ‘register’ and get their vaccine then?”

Accessing proof of comorbidity

Thirdly, for PLHIVs to be considered as part of Priority Group A3, they – along with other “adults with controlled comorbidities” – have to provide as proofs of comorbidity all or any of the following (issued within the past 18 months):

  1. Medical certificate from an attending physician;
  2. Prescription for medicines;
  3. Hospital records such as the discharge summary and medical abstract; and/or
  4. Surgical records and pathology reports

The idea behind the medical clearance makes medical sense, since – as stressed by the DOH memo – “the medical clearance process for these groups shall enable individual risk-benefit assessment by the attending physician.”

The DOH memo stated that the medical clearance must have “the full name of the attending physician and their corresponding contact details for verification. It shall be issued by licensed physicians or may also come from referral apex hospitals, through telemedicine and Rural Health Units.” The memo similarly stressed that “to reduce barriers in vaccination, LGUs shall ensure that the systems providing for medical clearances to the appropriate A3 subgroups shall be accessible and available to all members who need to secure a medical clearance prior to vaccination.”

But Quilacio lamented how this is “out of touch on the realities of PLHIVs,” he said. Getting a medical certificate from RITM, for instance, means scheduling a teleconsultation; and RITM’s online appointment booking is only open for less than half an hour, and schedules fill fast. As RITM itself states: “Magiging limitado ang time slots na bukas para sa pagkonsulta sa mga susunod na araw, maaring mabilis mapuno ito agad at mas maagang magsara ang Appointment System. Ibayong pag unawa ang aming hinihiling. Maraming salamat po.”

For Quilacio, “as the cliché goes, the devil is in the details.”

Photo by Artem Podrez from

Wanted: Simplified process/es

Quilacio said that DOH may have a lot to do, but this is exactly why simplified processes should be considered, instead of further convoluting processes. “Tell PLHIVs to go to their hubs; vaccinate them there. If their hubs are not available, then hubs that offer these vaccines and are closest to them should give the vaccines to them.”

Obviously, PLHIVs may choose not to abide by these guidelines to be included in the Priority Group A3. If this is taken as an option, they will then be included in the other categories; meaning they will get vaccinated later in the year or even in 2023, when the vaccination is already made widely available to the general public. For Quilacio, “while this is a personal choice, this defeats the purpose of prioritizing PLHIVs because they are at higher risk of getting COVID-19, or die from it due to more dire complications if they are infected by it.”

In the end, said Quilacio, sans steps to better vaccine access of PLHIVs, “I bet vaccines will already be given to Priority Group A4, etc and yet not even a quarter of PLHIVs (who are in A3) will have received their COVID-19 vaccination.”

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