Health Equity and Access to COVID-19 Treatments Available through Emergency Use Authorizations
Journal of Racial and Ethnic Health Disparities
https://doi.org/10.1007/s40615-024-02094-x
Health Equity and Access to COVID‑19 Treatments Available
through Emergency Use Authorizations
Candon Johnson1
· Carolyn Wolff2
· Jing Xu3
· On behalf of the N3C consortium
Received: 1 April 2024 / Revised: 8 July 2024 / Accepted: 10 July 2024
This is a U.S. Government work and not under copyright protection in the US; foreign copyright protection may apply 2024
Abstract
Understanding and evaluating equity in access to care is a critical component to ensuring health equity for all individuals.
During the COVID-19 pandemic, the U.S. Food and Drug Administration made unprecedented use of its regulatory authority
by authorizing the use of unapproved products through Emergency Use Authorizations (EUAs). We use data from the U.S.
National COVID Cohort Collaborative (N3C) to understand how access to therapeutic products authorized under EUAs has
varied across COVID-19 patients and over time. We find that Black patients were more likely to receive early EUA drugs
while White patients were more likely to receive monoclonal antibodies. Male patients were more likely to receive any
EUA drug than Female patients. Patients in Metropolitan areas were more likely to receive EUA drugs than patients in other
regions. Additionally, differences in the rates of exposure to EUA drugs by gender, rural-urban classification, and length of
stay decreased over time while differences by race and ethnicity have generally persisted. Our project identifies inequities in
the rate of access to EUA drugs across patient groups that can inform policy makers in future planning and decision making.
Keywords COVID-19 · Health Equity · Racial Health Disparities · Emergency Use Authorizations
MSC 62P25
Introduction
In order to achieve health equity for all individuals, we
need a better understanding of the heterogeneous impacts
of health policies across diverse populations. Understanding
how access to health care may vary across the United States
is a critical component of this goal. Prior to the COVID-19
pandemic, the overall trend in access to care was improving for minority and disadvantaged groups, although significant disparities by race, ethnicity, household income,
and location of residence remained [1]. While it is yet to
be determined how the overall COVID-19 pandemic may
have impacted these general trends, Alcendor (2020) finds
* Candon Johnson
1
Food and Drug Administration, Office of the Commissioner,
Silver Spring, MD, USA
2
Federal Trade Commission, Bureau of Economics,
Washington, DC, USA
3
Food and Drug Administration, Center for Drug Evaluation
and Research, Silver Spring, MD, USA
that communities of color and other underserved populations
living with limited access to social services have been particularly hard hit by the pandemic and continue to be among
the most vulnerable [2].
A key public health measure used during the COVID-19
pandemic was the authorization of medical products under
FDA’s Emergency Use Authorization (EUA) authority.
While FDA made unprecedented use of this authority during the pandemic to help expedite the availability of medical products and strengthen the public health protections,3
it is currently unknown what impact it has had on health
equity in the United States. In an effort to shed light in this
area, we examine the health equity associated with access to
drugs authorized under the FDA EUA authority during the
COVID-19 pandemic.
The EUA authority allows FDA to authorize unapproved
medical products or unapproved uses of previously approved
medical products to be used in an emergency. On February
4, 2020, the Secretary of Health and Human Services (HHS)
determined that there was a public health emergency involving the SARS-CoV-2 virus, which causes the COVID-19
illness. That determination provided the basis for justifying
Vol.:(0123456789)
Journal of Racial and Ethnic Health Disparities
1/18/2020
Chloroquine phosphate or hydroxychloroquine sulfate
Veklury (Remdesivir)
9/9/2020
6/23/2021 11/3/2021
4/25/2022
5/1/2020
4/16/2021
11/9/2020
Baricinib (Olumiant)
11/19/2020
REGEN-COV (Casirivimab and Imdevimab)
11/21/2020
Bamlanivimab and Etesevimab
1/24/2022
1/24/2022
2/9/2021
Sotrovimab
4/5/2022
5/26/2021
Actemra (Tocilizumab)
6/24/2021
Evusheld (Tixagevimab co-packaged with cilgavimab)
12/8/2021
Paxlovid (Nirmatrelvir/Ritonivir)
12/22/2021
Lagevrio (Molnupiravir)
12/23/2021
Bebtelovimab
EUA without a revocaon/ terminaon
9/7/2022
6/15/2020
Bamlanivimab
EUA with a revocaon/ terminaon
3/23/2022
3/28/2020
2/11/2022
Jan-20 Mar-20 Jun-20 Sep-20 Dec-20 Mar-21 Jun-21 Sep-21 Dec-21 Mar-22 Jun-22 Sep-22
Date
Fig. 1 Drugs Authorized under an EUA for COVID-19
the authorization of emergency use of medical products during the COVID-19 pandemic [4]. FDA has since used the
EUA authority to authorize numerous vaccines, therapeutic
products, and medical devices to combat the COVID-19
pandemic.
By analyzing how access to drugs authorized under the
EUA authority for COVID-19 has varied across diverse
patient populations, our work contributes to the broader,
expanding literature on health equity. Previous studies in
this area have tended to focus on differences across race and
ethnicity using a convenience sample of patients or examining a subset of the drugs authorized for COVID-19 [5, 6].
Our study expands the literature in three ways. First, we use
data from the National COVID Cohort Collaborate (N3C),
the largest open U.S. database of patient electronic health
records representing more than 15 million patients observed
between January 2020 and September 2022 [7]. Second, we
include in our analysis all drugs ever authorized under an
EUA for COVID-19. Third, we seek to identify the presence
and size of any possible differences in the use of these drugs
for COVID-19 patients across a variety of demographic factors such as race, ethnicity, age, gender, and rural-urban classification, including how these differences changed over time
throughout the pandemic. Our findings suggest disparities
in EUA use during the COVID-19 pandemic and highlight
the need for future research to incorporate a comprehensive
set of controls for confounding factors to further understand
the causes of the disparities shown.
Data and Methodology
We first use the FDA’s website to identify drugs authorized
for COVID-19 under an EUA as of September 2022. The
website maintains lists of drugs with current EUAs and terminated or revoked EUAs [8]. Using these lists, we collect
the drug name, the date of first EUA issuance, and the date
of termination or revocation of the EUA if applicable. Each
drug is listed in Fig. 1 with the date of first EUA issuance
and the date of termination or revocation if applicable.1
We use data from the N3C to identify patients who
received EUA drugs authorized for COVID-19 [7]. The N3C
is the largest collection of COVID-19 data from electronic (...truncated)