Question Number: 190
PDR Number: SQ22-000108
Date Submitted: 24/02/2022
Department or Body: Department of Health

Attribution of a cause of death is not straightforward for COVID-19 in particular.

• When a person dies of COVID-19 alone, and not of the virus in conjunction with another illness, condition, or comorbidity, then that death can clearly be attributed to COVID-19.
• However, where COVID-19 was not the primary or secondary cause of death, it may still be a contributing factor. Death certificates include fields for clinicians to enter information about conditions or diseases leading directly to death, secondary causes as well as any other underpinning significant conditions that may have contributed to death but may not have been related to the conditions causing it (e.g., coronary artery disease, type 2 diabetes etc.).
• Whilst comorbidities can cause a person to be at higher risk of severe disease and death if they have COVID-19, the contribution of the pre-existing conditions and COVID to any death outcome relies on the treating clinicians’ judgement and can be difficult to ascertain.

In Australia, information on deaths from COVID-19 is collected through disease surveillance systems, and civil registration systems.

• COVID-19 cases and associated deaths are reported to the Australian Government Department of Health by the states and territories through the National Interoperable Notifiable Diseases Surveillance System (NINDSS).
• Additionally, the Australian Bureau of Statistics (ABS) compiles COVID-19 mortality data based on death registrations processed by the Registries of Births, Deaths and Marriages in each State and Territory and information on the cause of death sourced from a Medical Certificate of Cause of Death (MCCD) completed by a certifying practitioner.

COVID-19 associated deaths recorded in NINDSS are based on the surveillance case
definition outlined in the Communicable Diseases Network Australia COVID-19: National Guideline for Public Health Units (SoNG), see:
www1.health.gov.au/internet/main/publishing.nsf/Content/cdna-song-novelcoronavirus.htm

• As per the SoNG, a COVID-19 death is defined for surveillance purposes as: a death in a confirmed or probable COVID-19 case, unless there is a clear alternative cause of death that cannot be related to COVID-19 (e.g. trauma). There should be no period of complete recovery from COVID-19 between illness and death. Where a Coroner’s report is available, these findings are to be observed.

The reporting of an adverse event or death following vaccination to the Therapeutic Goods Administration (TGA) does not mean that the vaccine caused these events. The TGA strongly encourages consumers and health professionals to report suspected adverse events, even if there is only a very small chance a vaccine was the cause. Health professionals in New South Wales, Western Australia, Queensland, Northern Territory and Australian Capital Territory are required under public health legislation to notify all adverse events following immunisation to their state or territory health department. These reports are then submitted to the TGA.

All deaths reported to the TGA in people who have been recently vaccinated against COVID-19 are assessed by TGA staff, including medical officers and nurses to determine whether the information provided suggests a possible link between vaccination and the causes of death, or if further information is required to make an assessment. These case reviews consider the strength of the evidence available to determine whether the clinical conditions which led to a fatal outcome represent an emerging safety signal for the vaccine.

Adverse event reports with a fatal outcome remain in the TGA database even if they have not been assessed as vaccine related, so that they are included in analyses to detect safety signals based on patterns of reporting.

The TGA provides the total number of adverse event reports with fatal outcome, and the number assessed as vaccine related, in its weekly COVID-19 vaccine safety report.