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mortality.64 In addition, individuals living in low-income communities may have had more
<br />limited ability to socially distance or to self -isolate when ill, resulting in faster spread of the
<br />virus, and were over -represented among essential workers, who face greater risk of exposure.65
<br />Social distancing measures in response to the pandemic may have also exacerbated pre-
<br />existing public health challenges. For example, for children living in homes with lead paint,
<br />spending substantially more time at home raises the risk of developing elevated blood lead
<br />levels, while screenings for elevated blood lead levels declined during the pandemic.66 The
<br />combination of these underlying social and health vulnerabilities may have contributed to more
<br />severe public health outcomes of the pandemic within these communities, resulting in an
<br />exacerbation of pre-existing disparities in health outcomes.67
<br />Summary of the Interim Final Rule Approach to Public Health
<br />Summary: As discussed above, the interim final rule provided flexibility for recipients to
<br />pursue a wide range of eligible uses to "respond to" the COVID-19 public health emergency.
<br />Uses of funds to "respond to" the public health emergency address the SARS-CoV-2 virus itself,
<br />64 See, e.g., Centers for Disease Control and Prevention, Risk of Severe Illness or Death from COVID-19 (Dec. 10,
<br />2020), https://www.edc.gov/coronavirus/2019-ncov/community/health-equity/racial-ethnic-disparities/disparities-
<br />illness.html (last visited December 7, 2021).
<br />65 Milena Almagro et al., Racial Disparities in Frontline Workers and Housing Crowding During COVID-19:
<br />Evidence from Geolocation Data (Sept. 22, 2020), NYU Stern School of Business (forthcoming), available at
<br />https://papers.ssrn.com/sol3/papers.cfm?abstract id=3695249; Grace McCormack et al., Economic Vulnerability of
<br />Households with Essential Workers, JAMA 324(4):388-90 (2020), available at
<br />https://jamanetwork.com/journals/jama/fullarticle/2767630.
<br />66 See, e.g., Joseph G. Courtney et al., Decreases in Young Children Who Received Blood Lead Level Testing
<br />During COVID-19 — 34 Jurisdictions, January -May 2020, Morb. Mort. Wkly. Rep. 70(5):155-61 (Feb. 5, 2021),
<br />https://www.cdc.gov/mmwr/volumes/70/wr/mm7005a2.htm; Emily A. Benfer & Lindsay F. Wiley, Health Justice
<br />Strategies to Combat COVID-19: Protecting Vulnerable Communities During a Pandemic, Health Affairs Blog
<br />(Mar. 19, 2020), https://www.healthaffairs.org/do/10.1377/hblog20200319.757883/full/.
<br />67 See, e.g., Centers for Disease Control and Prevention, supra note 58; Benfer & Wiley, supra note 62; Nathaniel
<br />M. Lewis et al., Disparities in COVID-19 Incidence, Hospitalizations, and Testing, by Area -Level Deprivation —
<br />Utah, March 3-July 9, 2020, Morb. Mortal. Wkly. Rep. 69(38):1369-73 (Sept. 25, 2020),
<br />https://www.cdc.gov/mmwr/volumes/69/wr/mm6938a4.htm.
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