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Federal Register / Vol. 86, No. 227 / Tuesday, November 30, 2021 / Rules and Regulations
Table 14. Monetized Benefits Attributable to the Interim Final Rule, 3% Discount Rate
Value oflmpact
Low
Primary
High
COVID-19 Risk Reductions, Staff
$66,021,974

$110,059,221

$154,096,444

COVID-19 Risk Reductions, Volunteers
$126,754,066

$126,754,066

$126,754,066

Absenteeism Reductions
$3,210,121

$5,372,304

$7,534,486

Total Monetized Benefits
$195,986,161

$242,185,591

$288,384,996

Table 15. Monetized Benefits Attributable to the Interim Final Rule, 7% Discount Rate
Low
Primary
High
COVID-19 Risk Reductions, Staff
$68,206,983

$113,715,169

$159,223,331

COVID-19 Risk Reductions, Volunteers
$128,877,518

$128,877,518

$128,877,518

Absenteeism Reductions
$3,210,121

$5,372,304

$7,534,486

Total Monetized Benefits
$200,294,622

$247,964,991

$295,635,335

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In addition to the impacts that we monetize in this analysis, we anticipate that the increase in vaccine coverage attributable to the interim final rule will result in indirect health benefits from reduced transmission of SARSCOV2. These impacts include reductions in secondary infections from vaccinated Head Start staff and volunteers to other staff and volunteers, children, and families. We anticipate that the masking requirement will also reduce transmission at in-person Head Start settings from individuals covered by the requirement. This impact includes a reduction in COVID19
transmission from children to Head Start teachers, staff, and other children. The reductions in transmission attributable to the interim final rule will result in additional, unquantified reductions in mortality and morbidity risks to Head Start children and families, and to the general public.
We request comment on potential quantitative estimation of benefits for Head Start staff who receive exemptions associated with ancillary provisions and reduced exposure when colleagues are vaccinated using a study by Chen, Glymour, et al. 2021.131 In this paper, estimates of excess mortality among 18- to 65-year-olds in 131 Chen, Yea-Hung, Maria Glymour, Alicia Riley, John Balmes, Kate Duchowny, Robert Harrison, Ellicott Matthay, Kirsten Bibbins-Domingo. Excess mortality associated with the COVID19 pandemic among Californians 1865 years of age, by occupational sector and occupation: March through October 2020. medRxiv 2021.01.21.21250266; doi:
https doi.org/10.1101/2021.01.21.21250266.

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California during the eight months from March to October, 2020, are summarized across various industry categories, including teacher assistants, for whom the estimated ratio is 1.28.132 The unemployed or missing employment data category has an excess mortality risk ratio of 1.23which may yield a reasonable estimate of the new risk level in cases of rule-induced staff turnover. During most of the eight months covered by the Chen et al. study, California imposed stay-athome requirements, but these policies were relaxed somewhat during the early and midsummer, the result being an increase in COVID19 mortality. Visual inspection of Chen et al.s Figure 2 allows for estimation analogous to that described above, using the excess mortality risk ratios for August 1, and yielding a result that the scope for workplace safety improvements is lesser in the context of relatively free movement and activity, as compared with a situation of broader nonworkplace mitigation measures. In other words, whatever the overall effectiveness of Cal/OSHAs workplace health and safety requirementspresumably similar to this IFRs ancillary provisionsit should be 132 The list of occupations with specific estimates differs, omitting teacher assistants, in a subsequent version of the paper. Chen, Yea-Hung, Maria Glymour, Alicia Riley, John Balmes, Kate Duchowny, Robert Harrison, Ellicott Matthay, Kirsten Bibbins-Domingo. Excess mortality associated with the COVID19 pandemic among Californians 1865 years of age, by occupational sector and occupation: March through November 2020. PLoS One, June 4, 2021 https doi.org/
10.1371/journal.pone.0252454.

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reduced substantially when extrapolated to a context without widespread stay-at-home policies. An additional tendency toward overstatement in the potential estimation approach exists because it does not incorporate a netting off of the impacts of other jurisdictionsincluding Californias ownmitigation activities. In other words, it would be necessary to use the correct baseline before attributing benefits to this IFR. By contrast, this suggested quantification method has a tendency toward underestimation in that it does not account for reduction in exposure due to exemptionreceiving Head Start staff being surrounded by colleagues who are more widely vaccinated. In addition to seeking comment on how to address these challenges in a potential quantitative estimate of benefits for exemption recipients, we request feedback on the potential to use literature such as Chen, Glymour et al. to proxy the new risk level for non-turnover cases.
F. Costs of the Rule The most significant cost of the interim final rule stems from the potential for Head Start staff to decline COVID19 vaccination.
This would result in a number of potential consequences, each of which is likely to represent a substantial social cost. Table 16
presents the number of Head Start staff anticipated to be fully vaccinated under the vaccine coverage scenarios, under a shared assumption that 5% of Head Start staff will seek and receive an exemption from the vaccination requirement. Under the lowerbound vaccine coverage scenario, as many as
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