issued, it has for the last year decreased to very low levels, often zero, for weeks at a time.
75
An
unknown fraction of these deaths may have been vaccinated persons. Nor is there reason to
believe that the relatively few recently recorded deaths from COVID-19 were due to workplace
exposures, considering all the other locations at which workers might be exposed to the virus.
76
That said, we still do not know how much of this massive decrease in the mortality rate of
infected populations was due to the policy effects of the IFC itself, but with the educate and offer
rule now permanent, the fraction of staff and patients unvaccinated close to single digits (and
never likely to have been much closer to zero given the various legally available exemptions),
there is no plausible basis for estimating a resurgence of deaths among either group absent some
new and more virulent COVID variant.
Perhaps the simplest way to understand these effects is to consider that in the roughly 18
months since the staff vaccination IFC rule was issued, much and perhaps most of the originally
estimated costs (implementation) and benefits (lives saved) have already been realized.
However, the many uncertainties that still affect projections into the future led us to restrict our
cost horizons in the staff vaccination rule to one year and to eschew any mortality reduction
estimate. In retrospect, it appears that while our cost estimates may have been reasonably robust,
any estimate of lives saved would have likely been far too high. In particular, the reduced
lethality of the Omicron variant of the virus and the available treatments for those ill from the
virus were the largest life savers by far.
77
75
The CDC Data Tracker for Covid, “Cases and Deaths among Healthcare Personnel,” estimates the total number of
COVID-caused deaths among healthcare workers since the pandemic began is about 2,500, of which only about 200
have occurred in the last year (February to February). Data at https://covid.cdc.gov/covid-data-tracker/#health-care-
personnel_healthcare-deaths.
76
The Bureau of Labor Statistics estimates that there were about 5,000 annual fatal workplace injuries to workers in
recent years. Accidents at work are only one of many causes of worker fatalities (for example, automobile injuries
outside of the workplace, non-occupational illnesses of all kinds, and heart attacks while at work). In comparison,
roughly 200 healthcare worker deaths occurred from COVID-19, much and perhaps most contracted outside the
workplace. See CDC healthcare personnel data cited in preceding footnote, in comparison “to “National Census of
Fatal Occupational Injuries in 2021” at https://www.bls.gov/news.release/pdf/cfoi.pdf.
77 See W. Adjei et al., “Risk Among Patients Hospitalized Primarily for COVID-19 During the Omicron and Delta
Variant Pandemic Periods,” Morbidity and Mortality Weekly Report (MMWR), September 16, 2022; at
https://www.cdc.gov/mmwr/volumes/71/wr/mm7137a4.htm. This report showed a two thirds reduction in mortality
from the Delta period to the Omicron period.