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COVID-19 continues to lead to large numbers of deaths, harms, and financial costs. Without an effective vaccine, those will continue. The pressure to find a vaccine is high; and that pressure places a risk on the safeguards in place to assure that vaccines are safe and effective will be ignored. The United States has an extensive apparatus to oversee vaccine safety before and after licensing, including multiple federal committees and several monitoring systems, and that apparatus gave us, in 2020, an extraordinarily safe vaccine supply. This Article explains the different pressures that push for and against using the same apparatus for COVID-19 vaccines, including the extensive harms from the disease on one side and the need for a vaccine that is, in fact, safe and effective on the other. It examines the options for speeding up the process without sacrificing too much oversight. It examines which “shortcuts” are reasonable, which may be challenging, and which are bad ideas. Finally, it addresses three messaging challenges—overselling, under-sharing, and responding to misinformation—and suggests how to handle them.

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Administrative Law Review Accord