Court filing

Declaration of Cole Beeler, M.D. — Klaassen v. Indiana University

Record facts

Court	U.S. District Court for the Northern District of Indiana
Filed	2021-07-12

U.S. District Court for the Northern District of Indiana · No. 1:21-cv-00238-DRL-SLC · Doc. 21-1 · 2021-07-12 · Docket on CourtListener

Summary

The declaration of Cole Beeler, M.D., submitted as Exhibit A in Klaassen v. The Trustees of Indiana University, Case No. 1:21-cv-00238, in the U.S. District Court for the Northern District of Indiana, stamped as document 21-1 filed July 2, 2021 and document 31-16 filed July 12, 2021. The declarant states he is an Assistant Professor of Clinical Medicine at the Indiana University School of Medicine and serves on Indiana University's Restart Committee. The declaration describes COVID-19 transmission and groups at increased risk of severe illness, and cites over 750,000 confirmed cases and over 13,000 deaths in Indiana since March 6, 2020 and almost 12,000 student positive tests at IU since July 2020. It addresses the three COVID-19 vaccines available in Indiana and variants, and responds to the plaintiffs' expert on herd immunity. The document is 38 pages and attaches the declarant's C.V.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

______________________

EXHIBIT A
______________________

USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 1 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 1 of 38

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
FORT WAYNE DIVISION

RYAN KLAASSEN, JAIME CARINI, )
D.J.B., by and though his next friend and
)
father, DANIEL G. BAUMGARTNER,
)
ASHLEE MORRIS, SETH CROWDER,
)
MACEY POLICKA, MARGARET ROTH, )
and NATALIE SPERAZZA,
)

)

Plaintiffs,
)
Case No. 1:21-cv-00238

)
vs.

)

)
THE TRUSTEES OF INDIANA
)
UNIVERSITY,

)

Defendant.
)

DECLARATION OF COLE BEELER, M.D.

I.
Background
1.
I am over 18 years of age. This declaration is based upon my own personal and
professional knowledge and experience.
2.
I am competent to testify as a medical expert to the facts and matters set forth
herein. A true and accurate copy of my C.V. is attached hereto as Exhibit A.
3.
I am currently an Assistant Professor of Clinical Medicine at the Indiana
University School of Medicine. I earned my B.S. and my M.D. from Indiana University.
4.
I am dual Board certified by the American Board of Internal Medicine in
Infectious Disease and Internal Medicine. I am a member of the Infectious Diseases Society of
America.
5.
I am a member of Indiana University’s Restart Committee. I serve on its
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 2 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 2 of 38

Modeling and Data Monitoring subgroup.
II.
Analysis
A. COVID-19
6.
COVID-19 is an infectious disease caused by the novel coronavirus (SARS-CoV-
2) that primarily spreads through respiratory droplets and aerosol transmission.
7.
People of all ages can contract and transmit COVID-19.
8.
People who catch COVID-19 may suffer from immediate severe illness and/or
suffer long-term ongoing health problems, extending several weeks or months. Individuals
infected with COVID-19 can suffer these long-term negative health effects even if they were
initially asymptomatic. COVID-19 can also be fatal. CDC, Benefits of Getting a COVID-19 Vaccine,
https://www.cdc.gov/coronavirus/2019-ncov/vaccines/vaccine-benefits.html.
9.
Certain types of individuals are at increased risk of suffering severe illness or
death if they contract COVID-19, and thus are more likely to need more serious medical
intervention, including hospitalization, intensive care, and a ventilator. Individuals who are at
increased risk of suffering severe COVID-19 include:
a. Adults over age 45;
b. Disabled individuals;
c. Members of many racial and ethnic minority groups;
d. Immunocompromised individuals;
e. Current or former smokers;
f. Individuals who are overweight or obese;
g. Individuals who have received organ or blood stem cell transplants;
h. Individuals who have suffered a stroke; and
i. Individuals with certain other underlying medical conditions, including, among
others, cancer, chronic kidney disease, chronic lung diseases, dementia and other
neurological conditions, diabetes (type 1 or type 2), Down syndrome, heart
conditions, HIV infection, liver disease, sickle cell disease, cerebrovascular
disease, and substance use disorders.
CDC, People with Certain Medical Conditions, https://www.cdc.gov/coronavirus/2019-
ncov/need-extra-precautions/people-with-medical-conditions.html; CDC, People with
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 3 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 3 of 38

Underlying Medical Conditions at Increased Risk from COVID-19,
https://www.cdc.gov/coronavirus/2019-ncov/vaccines/recommendations/underlying-
conditions.html.
10.
Even though COVID-19 more often affects children less severely than adults,
COVID-19 has also been shown to cause severe illness in children. Like adults, children with
underlying medical conditions are at increased risk of suffering more severe illness if they
contract COVID-19.
11.
Additionally, all individuals, including children, who contract COVID-19 risk
giving it to others, including friends, family, and other individuals with whom they interact, who
may suffer severe illness or death.
B. Brief History of the Pandemic
12.
COVID-19 was first identified in Wuhan, China in late 2019.
13.
According to the Indiana State Department of Health (“ISDH”), Indiana’s first
case of COVID-19 was confirmed on March 6, 2020, and Indiana’s first COVID-19-related
death was reported on March 16, 2020. See Indiana’s Novel Coronavirus Response (last visited June
27, 2021), available at: https://www.coronavirus.in.gov/ (“IN COVID-19 Response”).
14.
Since March 6, 2020, Indiana has had over 750,000 confirmed COVID-19 cases
and over 13,000 deaths. See Indiana COVID-19 Data Report, https://www.coronavirus.in.gov/.
According to the CDC, an estimated 25.8% of Indiana’s population has been infected with
COVID-19. 18.4% of Indiana’s positive COVID-19 cases have been reported by individuals
between the ages of 20 and 29. Individuals aged 20 through 29 have reported more positive
COVID-19 cases than any other age demographic. A small number of those individuals also
have died from the virus.
15.
The CDC currently estimates that there have been approximately 33.5 million
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 4 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 4 of 38

cases of COVID-19 in the United States and over 600,000 people have died from COVID-19 in
the United States. See CDC, COVID Data Tracker, Nationwide Commercial Laboratory Seroprevalence
Survey, https://covid.cdc.gov/covid-data-tracker/#national-lab.
16.
Nationwide, individuals aged 20-29 accounted for more than 20% of all
confirmed COVID-19 cases between June and August of 2020. CDC, Changing Age Distribution of
the COVID-19 Pandemic-United States, May-August 2020 (pub. Oct. 2, 2020),
https://www.cdc.gov/mmwr/volumes/69/wr/mm6939e1.htm.
17.
The New York Times reports that over 700,000 cases of COVID-19 have been
linked to colleges and universities in the U.S. since the pandemic began and more than 260,000
COVID-19 cases have been linked to colleges and universities just since January 1, 2021.
Tracking Coronavirus Cases at U.S. Colleges and Universities, The New York Times,
https://www.nytimes.com/interactive/2021/us/college-covid-tracker.html.
18.
Since July 2020, IU has had almost 12,000 students test positive for COVID-19.
See IU COVID-19 Testing Dashboard, https://www.iu.edu/covid/dashboard/all.
C. COVID-19 Vaccinations
19.
We are likely to stop the spread of COVID-19 only when we achieve population
immunity, also known as “herd immunity.”
20.
Widespread COVID-19 vaccination is a critical tool in achieving herd immunity.
21.
The scientific community has not yet determined the percentage of people who
need to be protected from COVID-19 to achieve herd immunity. In fact, because the virus
continues to mutate, which results in variants, experts remain unsure whether achieving herd
immunity from COVID-19 is truly possible.
22.
Consequently, vaccinating individuals against COVID-19 currently is the leading
prevention strategy to protect individuals from the virus and end the pandemic. CDC, Guidance
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 5 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 5 of 38

for [IHEs], https://www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/index.html.
23.
There are three COVID-19 vaccinations available in Indiana at no cost: the Pfizer-
BioNTech vaccine, the Moderna vaccine, and the Johnson & Johnson vaccine (collectively,
“COVID-19 Vaccines”). See State of Indiana Vaccination Information and Planning, About the vaccine,
https://www.coronavirus.in.gov/vaccine/.
24.
Each of the COVID-19 Vaccines has been proven safe and effective. COVID-19
Vaccine: It’s our shot, Hoosiers (updated June 5, 2021),
https://www.coronavirus.in.gov/files/21_IN%20Vaccine%20effectiveness_6-2.pdf at 1; see also, e.g.,
ISDH COVID-19 Vaccine FAQs at 1,
https://www.coronavirus.in.gov/files/General%20Tool%20Kit%20Condensed%20FAQ%20and%20Links
%203.29.21.pdf (“The vaccine has been found in trials to be 95 percent effective in preventing COVID-
19 infections . . .”). Each was developed using long-standing science and scientific techniques that
are not experimental. Each went through all the federally mandated stages of clinical trials,
which include extensive testing and monitoring. Each has received and continues to undergo the
most intensive safety monitoring in U.S. history. The fact that the COVID-19 Vaccines are
currently available under Emergency Use Authorization in no way undermines their safety or
efficacy.
25.
The COVID-19 Vaccines are extremely unlikely to cause serious side effects that
could result in long-term health problems. CDC, Safety of COVID-19 Vaccines,
https://www.cdc.gov/coronavirus/2019-ncov/vaccines/safety/safety-of-vaccines.html.
26.
The COVID-19 Vaccines help prevent the spread of COVID-19 and are effective
against the COVID-19 variants that have been detected in Indiana. ISDH, Variant Details,
https://www.coronavirus.in.gov/map/VariantDetails.pdf.
27.
Because it takes the human body time to build antibodies to COVID-19,
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 6 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 6 of 38

individuals who receive a COVID-19 Vaccine are considered “fully vaccinated” two weeks after
their second dose of a two-dose vaccine or two weeks after a one-dose vaccine.
28.
Fully vaccinated individuals are less likely to catch COVID-19 if exposed to it
and less likely to spread it to others.
29.
The COVID-19 Vaccines also help stop mutation of COVID-19, which helps
prevent the emergence and spreading of variants.
30.
The COVID-19 Vaccines provide a known level of resistance to and protection
from COVID-19 for a sustained period of time. Conversely, while individuals who have had
COVID-19 might have some antibodies even after their infection has passed that provide
protection against COVID-19, the amount of protection that these individuals have against the
virus varies from person-to-person and wanes over time. As these individuals’ natural immunity
decreases, their risk of contracting COVID-19 increases.
31.
Accordingly, the CDC and the ISDH recommend that even individuals who have
had COVID-19 receive the COVID-19 Vaccine because the vaccine will provide these
individuals with additional protection against the virus. Frequently Asked Questions about COVID-
19 Vaccination, https://www.cdc.gov/coronavirus/2019-ncov/vaccines/faq.html.
32.
The CDC also recommends that children twelve and older receive the COVID-19
Vaccine as soon as possible because vaccinating minors helps to protect the minor, their families,
and other individuals with whom they interact.
33.
While the CDC has advised that it has received reports of myocarditis and
pericarditis in adolescents and young adults after COVID-19 vaccination, it and the ISDH still
recommend that all individuals age 12 and older receive a COVID-19 Vaccine because the
reports of myocarditis and pericarditis are rare and the benefits of COVID-19 vaccination still far
outweigh the known and potential risks. In fact, COVID-19 itself presents the risk of myocarditis
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 7 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 7 of 38

and pericarditis. CDC Children & Teens; CDC, Myocarditis and Pericarditis Following mRNA COVID-
19 Vaccination, https://www.cdc.gov/coronavirus/2019-ncov/vaccines/safety/myocarditis.html.
34.
Additionally, people with underlying medical conditions can receive the COVID-
19 vaccine as long as they have not had an immediate or severe allergic reaction to a COVID-19
Vaccine or its ingredients.
D. Current COVID-19 Risks
35.
The COVID-19 pandemic is ongoing. Currently, the CDC advises that the risk of
community transmission of COVID-19 in Indiana is “moderate.” Hoosiers continue to report
hundreds of new COVID-19 cases each day.
36.
Additionally, variants of the COVID-19 virus continue to develop and spread
throughout the country. These variants increase the risks associated with contracting and
spreading COVID-19 because they spread more easily than the original strain of COVID-19 and
can cause more severe infection.
37.
Indiana, specifically, has seen an increase in variants of the original COVID-19
strain. Over 60% of the samples tested in Indiana are positive for a variant, and the most recent
variant—the Delta variant—is confirmed to be present in Indiana.
38.
COVID-19 remains a particular threat to those who are unvaccinated.
39.
According to the ISDH, unvaccinated Hoosiers constitute 99.3% of COVID-19
cases in Indiana, and the odds of an unvaccinated Hoosier who contracts COVID-19 being
hospitalized are 1 in 525, as compared to 1 in 50,394 for fully vaccinated Hoosiers.
https://www.coronavirus.in.gov/files/21_IN%20Vaccine%20effectiveness_6-2.pdf.
40.
IU’s ability to consistently test its students for COVID-19, particularly those
individuals who are unvaccinated, is critical to its ability to respond quickly to COVID-19
outbreaks and help stem the spread of the virus as we work towards herd immunity. If IU is
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 8 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 8 of 38

unable to regularly test its unvaccinated students for COVID-19, the risk of undetected viral
spread on IU’s campuses and surrounding communities increases significantly and may even
affect vaccinated or previously infected constituents via viral breakthrough.
E. Response to Plaintiffs’ Expert
41.
Although COVID rates are declining, the etiology behind this is potentially
obscured by improved weather (temperature, humidity, UV all favorable for blunting
transmission). SARS-2 is a respiratory virus and will likely have seasonality like other
respiratory viruses. Murray, Piot, The Potential Future of the COVID-19 Pandemic: Will SARS-
CoV-2 Become a Recurrent Seasonal Infection, https://jamanetwork.com/journals/jama/article-
abstract/2777343. Coupled with an unknown fraction of the population that has neither been
infected or vaccinated, uncertain durations of clinical immunity after natural infection, and the
potential for breakthrough variants (e.g. B 1617-2), the state of the pandemic over the coming
winter is still very uncertain.
42.
In my expert opinion, the degree of unknowns associated with all of Dr.
McCullough’s statements as well as significant risks to the collegiate and county communities
that can be effectively avoided with use of the vaccine, make a mandate the safest way to protect
our constituents, their families, and their counties from a second inevitable rise in cases over the
winter.
Herd Immunity
43.
Indiana has not reached herd immunity.
44.
Herd immunity is based on the infectivity and R0 of the virus. The herd immunity
threshold is still unknown for this virus. In fact, many authors do not believe herd immunity is
possible with this virus. Kadkhoda, Herd Immunity to COVID-19: Alluring and Elusive,
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 9 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 9 of 38

https://academic.oup.com/ajcp/article/155/4/471/6063411?login=true; Taylor, COVID-19: Is
Manaus the final nail in the coffin for natural herd immunity?)
https://www.bmj.com/content/372/bmj.n394.short; Tkachenko et al, Time-Dependent
Heterogeneity leads to transient suppression of the COVID-19 epidemic, not herd immunity,
https://www.pnas.org/content/118/17/e2015972118.short; Burki, Herd Immunity for COVID-19,
https://www.thelancet.com/journals/lanres/article/PIIS2213-2600(20)30555-
5/fulltext?utm_content=buffer6eaeb&utm_medium=social&utm_source=twitter.com&utm_cam
paign=buffer. The current director of the CDC mentions similar concerns:
https://www.foxnews.com/health/no-magic-target-herd-immunity-walensky. In total, calculations
like those set forth by Dr. McCullough are highly error prone because of uncertainly related to
the included variables. See https://www.nature.com/articles/d41586-021-00728-2.
College Aged Individuals and COVID-19
45.
Although the mortality rate for college aged students is lower than other age
groups, I disagree that there could be “no risk” of infection. The purpose of mass vaccination is
also to protect individuals who are at higher risk of poor outcome or unable to mount an effective
immune response. Older individuals, those with problems with their immune system, and those
on certain medications that interfere with the development of an immune response may not have
the same protections as a typical college-aged student when vaccinated or infected naturally with
the virus.
46.
We have learned over the last year that our students, faculty, and staff are very
much members of their communities; they interact and engage consistently within the counties in
which they live. In any epidemic, infections spread through vulnerable links in the chain until
eventually resulting in morbidity and mortality in hosts that are less protected. Indeed, our
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 10 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 10 of 38

constituency also includes a number of vulnerable individuals for both bad outcomes from
COVID as well as inability to mount a strong response to the vaccine.
47.
The goal of universal vaccination is not limited to individual protection (even
though there is very strong evidence for this), but includes community-wide protection — to
reduce the total amount of all exposures to COVID-19, not just infections. Each exposure is
potential for transmission to a vulnerable individual, and these vulnerable individuals may be
vulnerable by choice or despite their best efforts to be immune.
48.
In addition, the long-term consequences of natural COVID-19 infection are still
unknown. Even “long COVID” can affect young adults at high levels and lead to long term
debility. https://health.ucdavis.edu/health-news/newsroom/studies-show-long-haul-covid-19-
afflicts-1-in-4-covid-19-patients-regardless-of-severity/2021/03;
https://healthblog.uofmhealth.org/childrens-health/long-haul-covid-kids;
https://www.usnews.com/news/health-news/articles/2021-02-23/whats-wrong-with-me-young-
covid-survivors-battle-long-haul-symptoms. There is still much unknown here. Compared with
the Covid-19 Vaccines whose platforms have now been used for decades, the uncertainty around
the consequences of infection with a novel virus, especially in relation to long term side effects
and sequellae, presents an undue risk. Pardi et al, mRNA vaccines- a new era in vaccinology,
https://www.nature.com/articles/nrd.2017.243.
49.
In summary, though the morbidity and mortality rate in the college age group is
low, it is not zero. It is coupled with many unknowns, and infections in this population
potentially drive infections in the community.
50.
Moreover, not all studies exonerate students for contribution of spread in their
surrounding county. Bosslet, et al, The effect of in-person primary and secondary school
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 11 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 11 of 38

instruction on county-level SARS-COV-2 spread in Indiana,
https://www.medrxiv.org/content/10.1101/2021.03.17.21250449v1; Courtemanche et al, School
Reopenings, Mobility, and COVID-19 spread: Evidence from Texas,
https://www.nber.org/papers/w28753; Andersen et al, College Openings, Mobility, and the
Incidence of COVID-19, https://www.medrxiv.org/content/10.1101/2020.09.22.20196048v1; Lu
et al, Are College Campuses Superspreaders? A data-driven modeling study,
https://www.tandfonline.com/doi/full/10.1080/10255842.2020.1869221.
51.
Regional differences in county “spill-over” from campus epidemics are likely
related to variations in infection prevention strategies employed at the campuses with more
robust strategies leading to less “spill-over.” The most robust strategy is having as many people
immune as possible and this is best (and most safely) achieved by vaccination.
52.
All individuals are equally likely to catch COVID-19. There is no protection from
infectivity or infectiousness in the college age group. This group may be more likely to be
asymptomatic, but spread is certainly still very possible as IU and many other colleges across the
nation, experienced firsthand over the last year. https://www.nytimes.com/interactive/2020/us
/covid-college-cases-tracker.html.
Asymptomatic Spread
53.
Very quickly in the pandemic, the medical community learned that ignoring
asymptomatic spread of this virus leads to propagation. As many as 30% of patients with
COVID-19 never develop symptoms. Johansson et al, SARS-COV-2 Transmission from people
without COVID-19 symptoms and it is estimated that more than half of all transmissions are
from individuals who are asymptomatic; Johansson et al,
https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2774707. This assessment has
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 12 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 12 of 38

been supported by the CDC. Bender et al, https://wwwnc.cdc.gov/eid/article/27/4/20-
4576_article; Infectious viral loads start increasing before symptom development; Sakurai, et al,
Natural History of Asymptomatic SARS-COV-2 Infection,
https://www.nejm.org/doi/full/10.1056/NEJMc2013020; The Natural History and Transmission
Potential of Asymptomatic Severe Acute Respiratory Syndrome Coronavirus 2 Infection,
https://academic.oup.com/cid/article/71/10/2679/5851471.
54.
Isolation by symptoms alone is not the consensus opinion of medical experts,
which is why most states in the U.S. as well as around the world recommend quarantine of
exposed individuals. This is because symptoms do not predict infectivity and it is safer to stay
home through the duration of an infectivity window after an exposure in order to protect the
community.
55.
Masking is also an effective and evidence-based intervention to help stem the
spread of COVID-19, even in asymptomatic individuals. Although this protection is significantly
less potent than immunity by vaccination, ongoing masking of unvaccinated individuals is a
potential stopgap for those unable to be vaccinated. Unmasked and unvaccinated individuals put
themselves at additive risk of infection as well as those around them that are unable to be
vaccinated or mount a sufficient immune response.
COVID Treatments
56.
Reliable data on treatment for COVID-19 is still lacking. Most of the regimens
listed in Table 5 of Dr. McCullough’s Report (p. 16) have been proven to be ineffective in
clinical trials despite hypothesized benefit. Indeed, some have even caused patient harm.
57.
Vitamins and medications like:
Zinc (Yao, et al, The minimal effect of Zinc on the survival of hospitalized patients with
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 13 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 13 of 38

COVID-19: An observational study, Chest 2021);
Hydroxychloroquine (Lewis et al, The efficacy and safety of hydroxychloroquine for
COVID-19 prophylaxis: A systematic review and meta-analysis of randomized trials
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0244778; Kashour et
al, Efficacy of Chloroquine or hydroxychloroquine in COVID-19 patients: a systematic
review and meta-analysis,
https://academic.oup.com/jac/article/76/1/30/5919602?login=true);
Ivermectin (Schmith, et al, The Approved Dose of Ivermectin Alone is not the Ideal
Dose for the Treatment of COVID-19,
https://ascpt.onlinelibrary.wiley.com/doi/full/10.1002/cpt.1889);
Azithromycin (Escheverria-Esnal et al, Azithromycin in the treatment of COVID-19: a
review, https://www.tandfonline.com/doi/full/10.1080/14787210.2020.1813024);
Doxycycline (Narendrakumar et al, Potential effectiveness and adverse implications of
repurposing doxycycline in COVID-19 treatment,
https://www.tandfonline.com/doi/full/10.1080/14787210.2021.1865803);
Inhaled Budesonide (Agusti et al, Early Treatment with Inhaled Budesonide to prevent
clinical deterioration in patients with COVID-19,
https://www.thelancet.com/journals/lanres/article/PIIS2213-2600(21)00171-5/fulltext);
have not been studied in rigorous head-to-head trials to determine actual benefit, have negative
consequences, or have been associated with patient harm. Their use has been thoroughly
discredited and discouraged by the CDC/NIH. https://www.covid19treatmentguidelines.nih.gov/
about-the-guidelines/whats-new/.
58.
At IU Health and many other centers, the adult treatment regimen for COVID-19
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 14 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 14 of 38

includes Dexamethasone, Remdesivir, Tocilizumab, and Baricitinib. All of these agents are
restricted to patients who have moderate to severe disease (minimal requirement of supplemental
oxygen). Dexamethasone, Tocilizumab and Baricitinib are for patients with severe
manifestations for disease (high flow oxygenations, non-invasive mechanical ventilation, and
mechanical ventilation). These recommendations in the hospital are based on the high-quality
studies showing benefit in these populations; however, there is still back-and-forth data even
with these agents.
59.
The evidence base for treatment is still very uncertain as evidenced by the lack of
primary literature support for each individual regimen by Dr. McCullough. Successful outpatient
management of COVID in some patients can be very challenging, and even if an individual is
able to avoid hospitalization with investigational therapies, this does not speak to the
consequences of infectious spread in the people who they live with, their vulnerabilities, and
their ability to obtain care. Prevention still remains the key driver for avoiding morbidity and
mortality from COVID-19 of which the vaccines are our most potent tool.
COVID Vaccines
60.
All three COVID-19 Vaccines have been studied in robust multi-centered,
international, randomized-controlled trials and proven both effective and safe in millions of
people.
61.
All three COVID-19 Vaccines have demonstrated a very high rate of efficacy
(Pfizer 95%, Moderna 94.1%, Johnson & Johnson 72%).
https://www.yalemedicine.org/news/covid-19-vaccine-comparison. These rates are much higher
than annual influenza vaccination (30-60% effective depending on the year), which is a
mandated annual vaccine at many universities. Breakthrough infections are possible with any
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 15 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 15 of 38

vaccine, but when you look at the amount vaccinated, these numbers are very low (0.05% in
Indiana). https://www.whas11.com/article/news/health/coronavirus/indiana-covid-breakthrough-
case-vaccine-differences/417-e62d4d8a-a044-4816-a50b-aceddd6741e8). I would note that we
also have breakthrough cases after natural infection (0.65%).
https://www.eurekalert.org/pub_releases/2021-03/l-tls031821.php.
62.
Overall, these are some of the most effective vaccines that have ever been
developed.
63.
There is currently no evidence of genotoxicity, mutagenicity, teratogenicity and
oncogenicity in any of the EUA-approved COVID vaccines.
64.
A formal FDA approval for safety requires 6 months of data. These outcomes
would require decades of research (Kostoff et al, COVID-19 vaccine safety,
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7521561/) and are unnecessary based on the
mechanism of vaccine action. In the cell, DNA in the nucleus encodes for a messenger (RNA)
that leaves the nucleus and utilizes the cellular machinery in the cytoplasm to make proteins that
do the work of the cell. The RNA vaccines utilize cellular machinery to make a protein that looks
like the main target of our natural immune system to the SARS2 virus. The current lay public
suspicions regarding mutagenesis take a backwards view of how RNA works in the cell and are
not currently supported by consensus opinion. Since the vaccines do not interact with DNA, they
do not lead to mutations, gene damage, or the development of cancers. Cimolai et al, Do RNA
vaccines obviate the need for genotoxicity studies?
https://academic.oup.com/mutage/article/35/6/509/5995048?login=true;
https://www.mskcc.org/coronavirus/myths-about-covid-19-vaccines; https://news.llu.edu/health-
wellness/expert-debunks-5-covid-19-vaccine-misconceptions.
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 16 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 16 of 38

65.
There are many medications and vaccines that we use today that have not had
these studies. Investigation into these areas should be based on clinical suspicion and
hypothesized links of which there are neither currently for the three COVID-19 Vaccines.
Further hypothesized risks of the vaccine are dwarfed by the very real risk of actual COVID-19
infection among the college constituency and in their communities.
66.
While the three currently available vaccines are made of the building blocks of
RNA, they are not genes, but are messenger scripts for making a protein. Their safety has been
repeatedly confirmed in randomized controlled trials with no difference in adverse outcomes
between vaccinated and unvaccinated individuals. There is no evidence that the spike protein
itself injures our body’s organs. The spike is an entry receptor for the virus to get into cells and
the major target of our immune system. The spike protein itself cannot damage tissues, cause
infections, or lead to complications. The immune response to the spike protein may be associated
with some adverse outcomes like clotting and myocarditis; however, the risks of these outcomes
associated with the vaccine are dwarfed by the risks of these outcomes associated with COVID-
19 infection itself. Torjesen, COVID-19: Risk of cerebral blood clots from disease is 10 times
than from vaccination, study finds, https://www.bmj.com/content/373/bmj.n1005.full; Wise et al,
COVID-19: Should we be worried about reports of myocarditis and pericarditis after mRNA
vaccines?, https://www.bmj.com/content/373/bmj.n1635).
67.
As an example, the rate of myocarditis in all recipients is 13/1,000,000 vaccines
administered (32/1,000,000 in males aged 12-39).
https://www.cdc.gov/vaccines/acip/meetings/downloads/slides-2021-06/03-COVID-
Shimabukuro-508.pdf. In contrast, 2.3% of collegiate athletes who had recovered from COVID-
19 had evidence of myocarditis on heart imaging. Daniels et al, Prevalence of Clinical and
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 17 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 17 of 38

Subclinical Myocarditis in Competitive Athletes with Recent Sars-CoV-2 Infection: Results
from the Big Ten Covid-19 Cardiac Registry,
https://jamanetwork.com/journals/jamacardiology/fullarticle/2780548.
68.
The infection of COVID-19 itself puts college-aged students at higher risk for
myocarditis than the vaccine. In addition, all vaccine associated myocarditis patients have
survived and were treated effectively. https://whyy.org/articles/myocarditis-and-the-covid-19-
vaccine-what-to-know-about-rare-heart-inflammation/. Because of all of this, the CDC continues
to recommend COVID vaccination for this younger age group.
https://www.cdc.gov/coronavirus/2019-ncov/vaccines/safety/myocarditis.html.
69.
Although the risk of cerebral sinus thrombosis after the Johnson & Johnson
vaccine is significant, it occurs with incredibly low probability and there is no proof of causation
between the vaccination and myocarditis.
https://www.cdc.gov/vaccines/acip/meetings/downloads/slides-2021-04/03-COVID-
Shimabukuro-508.pdf. While the vaccines may have statistics that support an association of
adverse outcomes, it is important not to imply causality until we are sure. The Johnson &
Johnson vaccine provides very meaningful benefit to a college-aged population given its ease of
administration as one dose. Additionally, IU students are able to receive whichever of the three
COVID-19 vaccines they prefer if they are personally concerned about this potential association.
Vaccination after COVID-19 infections
70.
The CDC continues to recommend vaccination for those who have been infected
naturally with COVID-19 and there is emerging evidence that vaccination may provide a broader
spectrum of protection to variants than natural infection
(https://directorsblog.nih.gov/2021/06/22/how-immunity-generated-from-covid-19-vaccines-
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 18 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 18 of 38

differs-from-an-infection/).
71.
There is no strong data for or against vaccination after natural infection
https://www.nature.com/articles/d41586-021-01609-4. We may have this data in the future, but
right now, we do not have accurate ways to diagnose prior infection. This leads to huge
challenges with trying to figure out who does and does not need the vaccine. Until this data is
looked at in a systematic and controlled fashion, more “boosters” to immunity in the form of a
COVID-19 Vaccine are likely beneficial to avoiding infection even despite mild side effects that
are transient and benign.
72.
Another major concern will be availability of data. There will consistently be new
variants of COVID that will be selected out by vaccination and natural infection. These will be
allowed to continue to mutate as long as there is susceptible population available. We have much
better data for efficacy of vaccines against variants than we do for efficacy of natural immunity
against variants. This is because we know exactly when immunity is established and the
trajectory over time. Without vaccination, there will be lingering concerns about breakthrough
variants leading to reinfection that will be more difficult to study internationally and provide
guidance to the cohort of our population that has not gotten the vaccine.
73.
It is entirely possible that the vaccine provides a broader immunity than natural
infection. It may be that people who were previously infected have a higher rate of vaccination
side effects after the first dose of the vaccine, but these symptoms are generally mild and not
dangerous. There are no reports of serious, life-threatening safety concerns for previously
infected individuals.
74.
The preprint article from Raw et al referenced in paragraph 63 of Dr.
McCullough’s declaration references “severe side effects” which include fever, fatigue, myalgia,
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 19 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 19 of 38

arthralgia, and lymphadenopathy. From a clinical perspective, these are easily managed at home
with over-the-counter medications and do not require an escalation in care. This is a misleading
way to bucket side effect profiles, and even the most “severe” cited are mild in contrast to the
viral infection itself.
75.
We may learn that those previously infected do not need both shots of the
vaccine, but currently the CDC still recommends both doses even after natural infection. These
mild symptoms are acceptable from a public health perspective when weighed against the risks
of repeat natural infection (which can be truly severe, resulting in hospitalization or death).
76.
Additionally, we still have no reliable way to confirm previous exposure to
COVID. Serologic tests for COVID-19 “antibodies” have a wide range of specificity (and vary
across platform).
77.
Using a serologic test to equate to immunity is not evidence-based and not
recommended by the CDC. https://www.cdc.gov/coronavirus/2019-ncov/testing/serology-
overview.html.
78.
COVID also has syndromic overlap with many other respiratory infections and
previous consistent symptoms alone cannot be grounds for proof of immunity. Even if using the
gold standard PCR test, there is a wide range in duration of immunity after PCR positivity, and
PCRs can be positive for months after natural infection. This can make it very challenging to set
the onset of immunity for an individual. Pragmatically, the only surefire way to assure effective
immunity is vaccination.
Potential Adverse Events
79.
The Vaccine Adverse Event Reporting System (VAERS) is a passive reporting
system. This means anyone can report any symptom they want after vaccination. These are each
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 20 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 20 of 38

combed through in order to identify trends, but the majority of symptoms are mild and are a
result of the normal immune response to the vaccine.
80.
VAERS reports and percentages have to be taken into context with prevalence of
the disease. If there was a meningococcal pandemic and we were vaccinating individuals at
higher rates, we may see higher percentages of adverse events reported due to heightened public
awareness. It is not a fair comparison from a rare disease to a hyper-prevalent novel disease with
a new vaccine that has a lot of entrenched (and, in my opinion, inappropriate and unfounded)
public uncertainty.
81.
Additionally, it is important to distinguish between association and causation.
Adverse effects are possible with any vaccine, but the decision to administer the vaccine is based
on the assessment of benefit over that risk. Regarding the risk of adverse events in those 18 to 29
years old, it is not surprising they are reporting more given their more robust immune responses.
Again, most of these reports are of mild generalized symptoms.
82.
The literature referenced in paragraph 48 of Dr. McCullough’s declaration, cited
in support of the medical community acknowledging the adverse effects of vaccines, links to a
study in mice, not humans. Additionally, while the CDC does acknowledge these side effects,
they still continue to strongly encourage vaccination of all those eligible given the benefit to the
entire population.
83.
The British health regulator has also reviewed the data requested and concluded
the benefits outweigh the risks. https://healthfeedback.org/claimreview/yellow-card-scheme-for-
adverse-events-does-not-suggest-any-new-side-effects-of-covid-19-vaccines-tess-lawrie/.
IU’s Policies
84.
Indiana University will not be performing research on students or constituents
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 21 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 21 of 38

getting the COVID vaccine without their express consent and in alignment with the local IRB
policies and procedures. All studies proving efficacy and safety of the vaccine were done with
critical event committees, data safety monitoring boards, and ethics committees in place.
85.
IU only plans to mandate the vaccine in age groups approved by the FDA. While
the WHO recommended that vaccinating children was less urgent than adults, WHO still
recommended vaccination. https://healthfeedback.org/claimreview/the-world-health-
organization-states-that-covid-19-vaccination-for-children-is-less-urgent-but-doesnt-
recommend-against-it/. The CDC continues to recommend children 12 years and older get the
vaccine. https://www.cdc.gov/coronavirus/2019-
ncov/vaccines/recommendations/adolescents.html.
86.
IU’s COVID-19 Vaccine Policy allows exemptions for pregnant women. IU
follows the recommended CDC list for vaccine exemptions. https://www.cdc.gov/vaccines/covid-
19/clinical-considerations/covid-19-vaccines-us.html.
F. Conclusion
87.
In my expert opinion, a COVID-19 vaccine mandate is the only safe and reliable
way to assure lack of spread of COVID among our students and our communities and prevent
morbidity and mortality. While COVID does not necessarily cause disproportionate bad
outcomes in our constituency, any bad outcome from COVID is potentially avoidable with the
vaccines where the benefit dwarfs the potential rare risks that may not be causally linked. The
vaccines used for COVID are based on technology that has been developed over decades and
have repeatedly been shown to be safe when given to millions of patients. This is not
experimentation. This is application of known science to a novel pathogen with uncertain and
threatening immediate and long-term consequences to our students, faculty, staff, and
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 22 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 22 of 38

communities at large. Given that this virus can be infectious despite an asymptomatic host and
that not everyone can mount an immune response after vaccination, an individual’s choice to
remain unvaccinated puts others around them in the community at risk. Ultimately, the benefit
to multiple college students being vaccinated has far-reaching benefits for the community as it
relates to reduction in spread, avoidance of variant selection, and reductions in morbidity and
mortality going into an uncertain season.
III.
Selected List of Additional Materials Reviewed
1.
See, e.g., Centers for Disease Control & Prevention (“CDC”), COVID-19
Vaccines for Children and Teens (last visited June 27, 2021), available at:
https://www.cdc.gov/coronavirus/2019-ncov/vaccines/recommendations/adolescents.html
2.
CDC, Benefits of Getting a COVID-19 Vaccine (last visited June 27, 2021),
available at: https://www.cdc.gov/coronavirus/2019-ncov/vaccines/vaccine-benefits.html.
3.
CDC, People with Certain Medical Conditions (last visited June 27, 2021),
available at: https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-with-
medical-conditions.html
4.
CDC, People with Underlying Medical Conditions at Increased Risk from
COVID-19 (last visited June 27, 2021), available at: https://www.cdc.gov/coronavirus/2019-
ncov/vaccines/recommendations/underlying-conditions.html
5.
Indiana’s Novel Coronavirus Response (last visited June 27, 2021), available at:
https://www.coronavirus.in.gov/.
6.
CDC, Changing Age Distribution of the COVID-19 Pandemic-United States,
May-August 2020 (pub. Oct. 2, 2020), available at:
https://www.cdc.gov/mmwr/volumes/69/wr/mm6939e1.htm
7.
Tracking Coronavirus Cases at U.S. Colleges and Universities, The New York
Times (last updated May 26, 2021), available at:
https://www.nytimes.com/interactive/2021/us/college-covid-tracker.html
8.
CDC, COVID Data Tracker, Nationwide Commercial Laboratory Seroprevalence
Survey (last visited June 27, 2021), available at: https://covid.cdc.gov/covid-data-
tracker/#national-lab.
9.
Indiana COVID-19 Data Report (last visited June 27, 2021), available at:
https://www.coronavirus.in.gov/
10.
IU COVID-19 Testing Dashboard (last visited June 27, 2021), available at:
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 23 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 23 of 38

https://www.iu.edu/covid/dashboard/all.
11.
CDC, COVID-19 Vaccines Are Free to the Public (last visited June 27, 2021),
available at: https://www.cdc.gov/coronavirus/2019-ncov/vaccines/no-cost.html
12.
CDC, Key Things to Know about COVID-19 Vaccines (last visited June 27,
2021), available at: https://www.cdc.gov/coronavirus/2019-ncov/vaccines/keythingstoknow.html
13.
Harvard School of Public Health, Can herd immunity stop COVID-19? (last
visited June 27, 2021), available at: https://www.hsph.harvard.edu/news/hsph-in-the-news/can-
herd-immunity-stop-covid-19/.
14.
CDC, Guidance for [IHEs] (last visited June 27, 2021), available at:
https://www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/index.html
15.
State of Indiana Vaccination Information and Planning, About the vaccine,
available at: https://www.coronavirus.in.gov/vaccine/
16.
COVID-19 Vaccine: It’s our shot, Hoosiers (updated June 5, 2021), available at:
https://www.coronavirus.in.gov/files/21_IN%20Vaccine%20effectiveness_6-2.pdf
17.
ISDH COVID-19 Vaccine FAQs (last updated Mar. 31, 2021), at 1, available at:
https://www.coronavirus.in.gov/files/General%20Tool%20Kit%20Condensed%20FAQ%20and
%20Links%203.29.21.pdf
18.
ISDH COVID-19 Vaccine Fact Sheet (pub. Jan. 2021), available at:
https://www.coronavirus.in.gov/files/Fact%20Sheet.pdf
19.
CDC, Safety of COVID-19 Vaccines (last visited June 27, 2021), available at:
https://www.cdc.gov/coronavirus/2019-ncov/vaccines/safety/safety-of-vaccines.html
20.
ISDH, Variant Details (last visited June 27, 2021), available at:
https://www.coronavirus.in.gov/map/VariantDetails.pdf
21.
CDC COVID-19 Info., Frequently Asked Questions about COVID-19 Vaccination
(last visited June 27, 2021), available at: https://www.cdc.gov/coronavirus/2019-
ncov/vaccines/faq.html
22.
CDC, Myocarditis and Pericarditis Following mRNA COVID-19 Vaccination
(last visited June 27, 2021), available at: https://www.cdc.gov/coronavirus/2019-
ncov/vaccines/safety/myocarditis.html
23.
Declaration of Peter A. McCullough, MD, MPH (June 28, 2021)
IV.
Other Testimony & Compensation
I have not previously provided expert testimony in litigation.
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 24 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 24 of 38

This declaration is being provided in addition to my duties of teaching, patient care, and service
on the Restart Committee. I am being compensated for my work in this matter at a rate of $500
per hour.

USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 25 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 25 of 38

USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 26 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 26 of 38

Exhibit A
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 27 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 27 of 38

1
CURRICULUM VITAE

NAME: Cole Beeler
Contact Information:
Emerson Hall, Rm 445
Indianapolis, IN, 46202
T: 317-274-7943
F: 317-944-8660

EDUCATION:

POSTDOCTORAL

Institution
Degree
Date
Awarded
Indiana University School of Medicine
Internship, Internal Medicine
2012
Indianapolis, IN
Residency, Internal Medicine
2015

Fellowship, Infectious Diseases
2017
GRADUATE

Institution
Degree
Date
Awarded
Indiana University School of Medicine
M.D.
2011
Indianapolis, IN

UNDERGRADUATE

Institution
Degree
Date
Awarded
Indiana University
B.S. Biology
2007
Bloomington, IN

APPOINTMENTS:

ACADEMIC

Institution
Rank
Inclusion dates
Indiana University School of Medicine
Assistant Clinical Professor
7/2017 to
current
Indiana University School of Medicine
Associate Fellowship Director
12/2018 to
current
Indiana University School of Medicine
Key Clinical Educator for Division of Infectious
Diseases
12/2018 to
current
Indiana University School of Medicine
Director of Symptomatic Testing, COVID Medical
Response Team
5/2020 to
current

NON-ACADEMIC

Institution
Rank
Inclusion dates
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 28 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 28 of 38

2
Indiana University Health
University Hospital Medical Director of Infection
Prevention and Control
7/2017 to
current

LICENSURE, CERTIFICATION, SPECIALTY BOARD STATUS

Credential
Number
Inclusion dates
Indiana Medical License
01074103a
5/30/2014 to
10/31/2021
Certification in Internal Medicine
354639
2014-2024
Certification in Infectious Diseases
354639
2017-2027

PROFESSIONAL ORGANIZATION MEMBERSHIPS:

Organization
Inclusive Dates
Infectious Disease Society of America
2015 to current

PROFESSIONAL HONORS AND AWARDS:

SERVICE

Award Name
Granted By
Date Awarded
Outstanding Intern- Internal Medicine
Internal Medicine Residency
2012
Outstanding 3rd year Resident- Internal Medicine
Internal Medicine Residency
2015
Resident's Choice Fellow of the Year
Internal Medicine Residency
2016
Outstanding Young Clinician Award
Indiana University School of Medicine
2020
IU Bicentennial Medal Award
Indiana University
2020
System Services Values Leadership Award
Indiana University Health
2020

OVERALL/OTHER

Award Name
Granted By
Date Awarded
Jay Thomas Memorial Award in Physiology
Indiana University School of Medicine
2008
John Van Nuys Memorial Fellowship
Indiana University School of Medicine
2008
Class of 1978 R.C. Powell Scholarship
Indiana University School of Medicine
2009
Charles C. Odya Award in Pharmacology
Indiana University School of Medicine
2009
Ronald H. Doneff Scholarship
Indiana University School of Medicine
2010
Gold Humanism Honor Society
Indiana University School of Medicine
2012

PROFESSIONAL DEVELOPMENT:

Course/Workship Title
Provider
Date

Eskenazi Hospital Chief Residency
Indiana Unversity School of Medicine
2015-2016
Clinical Education Teaching Program
Indiana University School of Medicine
2017
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 29 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 29 of 38

3
Sailing the High Seas Leadership Development
Indiana University Health
2017
IU Talk Session
Indiana University Health
2017
Redcap Training
Indiana Unversity School of Medicine
2018
The Value of Social Media
Indiana Unversity School of Medicine
2018
Medical Education Combinator
Indiana Unversity School of Medicine
2018

TEACHING:

TEACHING ASSIGNMENTS:

POSTGRADUATE

Course #
Short Title
Format
Role
Term
93MD700
Clinical Infectious
Disease
Clinical
Director
2018 to current
93MD710
Infectious Disease
Research Elective
Research
Director
2018 to current
93MI690
MS3 Medicine
Clerkship- ID
Clinical
Sub-Director
2019 to current

MENTORING

Individual
Role
Inclusive Dates
Zahir Sheikh
Medical School Research Mentor
2018-2019
Brenna McElderry
Medical School Mentor
2018-2019
Kishan Shah
Medical School Mentor
2018-2019
Braden Sciarra
Medical School Mentor
2018-2019
Arefin Chowdhury
Residency Research Mentor
2018-2019
Madhu Reddy
Fellowship Research Mentor
2017-2019
Madiha Tahir
Fellowship Mentor
2017-2019
Jonathan Ryder
Residency Research Mentor
2018-2020
Jaewon Jung
Medical School Mentor
2018-2019
Junstin Hendrix
Medical School Mentor
2019-2020
Nick Litchin
Medical School Mentor
2019-2020
Wiaam Elkhatib
Medical School Mentor
2019-2020
Chizelle Onochie
Medical School Mentor
2018-2020
Amanda Agard
Fellowship Mentor
2018 to current
Humaira Khan
Medical School Mentor
2020 to current
Matthew Stack
Residency Research Mentor
2020 to current
Yebon Oh
Medical School Mentor
2020 to current
Taylor Munsch
Medical School Mentor
2020 to current
Aaron Smith
Medical School Mentor
2020 to current
Omar Elsheikh
Fellowship Research Mentor
2021 to current
Beth Nagel
Residency Research Mentor
2021 to current
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 30 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 30 of 38

TEACHING ADMINISTRATION AND CURRICULUM DEVELOPMENT:

Associate Fellowship Director
Fellowship in Infectious Diseases
2018 to current
ID Clinical Track Development
System for structure of ID Fellowship
2018 to current
Infection Prevention Curriculum
Curriculum for Infectious Disease
Fellows
2018 to current
Antibiotic Stewardship Curriculum
Implementation and Development of
IDSA curriculum to fellows
2019 to current
Advanced Antibiotic Stewardship
Curriculum
Implementation and Development of
IDSA curriculum to fellows
2021 to current
VIPER: YouTube Channel
(https://www.youtube.com/channel
/UC3HwM1yj5nhPOjWffgGrM9Q/vid
eos)
Videos for training and education in
Infection Prevention for IU Health
2019 to current
eRVU educational development
Training for the Division of Infectious
Diseases
2019 to current
Special Elective in ID
"Build your own elective"
implementation with the Internal
2019 to current
Delivering Appropriate Feedback
Training for the Division of Infectious
Diseases
2020 to current
ID Clinical Conference Director
Weekly Lecture with attendees from
across the state and country
2019 to current

INVITED PRESENTATIONS- TEACHING

LOCAL

Title
Organization
Date
Intern Core Lecture Series
Indiana University School of Medicine
2014 to 2016 (yearly)
University ID Clinical Conference
Indiana University School of Medicine
2015 to current (monthly)
Eskenazi ID Clinical Conference
Indiana University School of Medicine
2015 to 2020 (monthly)
Methodist ID Clinical Conference
Indiana University School of Medicine
2015 to 2020 (monthly)
Infectious Disease Curriculum Session:
Endocarditis
Indiana University School of Medicine
2015 to current (monthly)
Quality Minute: 3 Arm Gowns
Indiana University Health
2017
Host Defense Medical Student Lecture
Indiana University School of Medicine
2017
C diff Guideline Update
Indiana University School of Medicine
2018
Let me see that 1,2 Step VIPER
Indiana University Health
2018
Osteomyelitis for the Nurse
Practitioner
Eskenazi Health
2018
Your Foley is Contaminated VIPER
Indiana University Health
2018
Empiric Antibiotics
Eskenazi Health
2018
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 31 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 31 of 38

5
HIV for Residents
Indiana University School of Medicine
2018
IMPACT: GI Infections
Indiana University School of Medicine
2018
Immunodeficiency for Residents
Indiana University School of Medicine
2018 to current (monthly)
Procalcitonin for Hospitalists
Indiana University Health
2018
UTI for Hospitalists
Indiana University Health
2018
Quality Minute: Two Step C diff
Testing
Indiana University Health
2018
Urology C Diff Lecture
Indiana University Health
2018
Quality Minute: Influenza
Indiana University Health
2018
Transplant Quality Review
Indiana University Health
2018 to current (monthly)
Grand Rounds- Oyez Lectures
Indiana University School of Medicine
2019
Seeing a Difference in C diff
Indiana University Health
2019
STD Lecture for Clinical Therepeutics
Indiana University School of Medicine
2019
Procalcitonin VIPER
Indiana University Health
2019
Isolation 2.0 VIPER
Indiana University Health
2019
CHG VIPER
Indiana University Health
2019
Winter is Coming VIPER
Indiana University Health
2019
IMPACT: Pneumonia
Indiana University School of Medicine
2019, 2020
Aint' Nothin but a CHG Thang VIPER
Indiana University Health
2019
MICU Residen Orientation
Indiana University Health
2019 to current (monthly)
SICU Resident Orientation
Indiana University Health
2019 to current (monthly)
IMPACT: Antibiotic Stewardship
Indiana University School of Medicine
2019
Chest Conference: MICU HAI Review
Indiana University Health
2019
Is a Foley ever Indicated
Eskenazi Health
2019
Critical Care Grand Rounds- Is a Foley
Ever Indicated
Indiana University School of Medicine
2019
Chest Conference: PPE Use
Indiana University School of Medicine
2020
C diff Lecture for GI Fellows
Indiana University School of Medicine
2020 to current (yearly)
Dermatology Grand Rounds-
Ectoparasites
Indiana University School of Medicine
2020
Ophthalmology Grand Rounds- COVID
Indiana University School of Medicine
2020
Chaplaincy Department lecture- COVID
Indiana University Health
2020
GME PPE Training Video for new
resident orientation
Indiana University School of Medicine
2020
EMS Lecture- COVID
Indiana University Health
2020
HIV Lecture for GI Fellows
Indiana University School of Medicine
2021
Diagnostic Stewardship for General
Surgery
Indiana University School of Medicine
2021
Chest Conference: COVID
Indiana University School of Medicine
2021

REGIONAL

Title
Organization
Date
HIV Update for Family Practice
Indiana Academy of Family Physicians
2018
Community Acquired Pneumonia
Union Hospital
2018-2020 (yearly)
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 32 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 32 of 38

6
Is a Foley Ever Indicated?
APIC Regional Meeting
2019
Everyone's Infectious
Union Hospital
2019
Influenza Update
IUH E. Washington Clinic
2019
COVID Update
One America
2020
COVID Town Hall
IUPUI
2021 (x3)

NATIONAL

Title
Organization
Date
Teaching During COVID
ID Week (IDSA)
2020

SERVICE:

UNIVERSITY SERVICE

DEPARTMENT

Acitivity
Role
Inclusive Dates
Infectious Diseases Fellowship
Associate Fellowship Director
2018 to current
Key Clinical Educator
Division Representative
2018 to current

SCHOOL

Acitivity
Role
Inclusive Dates
Teaching Awards Committee
Member
2019 to current
Curriculum Council Clinical
Component Committee
Member
2019 to 2020
Faculty Commnity Relations
Committee
Member
2019 to 2020
Faculty Steering Committee
FCRC representative
2019 to 2020

CAMPUS

Acitivity
Role
Inclusive Dates

UNIVERSITY

Acitivity
Role
Inclusive Dates
COVID Medical Response
Team
Director of Symptomatic Testing
2020 to current
COVID Outbreak Investigation
and Response Team
Member/Reviewer
2020 to current
COVID Symptomatic testing
Transition Team
Member
2020 to current
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 33 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 33 of 38

7
EALC Meetings- COVID
Updates for President
McRobbie
Presenter
2020 to current (weekly)
President's Cabinet Meetings-
COVID updates
Presenter
2020 to current
(biweekly)
IU Regional Dean's Meetings-
COVID updates
Presenter
2020 to current
(biweekly)
IU COVID Restart Committee
Member
2020 to current
IU Education Restart
Committee
Member
2020 to current
GME Coronavirus Rapid
Response Team
Member
2020 to current

PROFESSIONAL SERVICE

LOCAL

Organization
Activity
Inclusive Dates
Indiana University Health
Infection Control Research Committee
2017 to current
Indiana University Health
System Infection Control Committee
2017 to current
Indiana University Health
IP/MD System Dyad Committee
2017 to current
Indiana University Health
Quality Improvement Committee
2017 to current
Indiana University Health
Hand hygiene committee
2017 to 2020
Indiana University Health
CLABSI Harm Team
2017 to 2020
Indiana University Health
C diff Harm Team
2017 to 2020
Indiana University Health
Antibiotic Stewardship Committee
2017 to current
Indiana University Health
AIM Pathology Laboratory Committee
2017 to current
Indiana University Health
MICU end of life culturing QI project
2018
Indiana University Health
CLABSI Harm Team Toolkit Development
2018
Indiana University Health
Poor Peripheral Access Algorithm
2018
Indiana University Health
Foley Point Prevalence Survey
2018
Indiana University Health
3E CLABSI Project
2018
Indiana University Health
Device Round Standardization
2018
Indiana University Health
Abdominal Transplant Quality Committee
2018 to current
Indiana University Health
CAUTI Harm Team
2018 to 2019
Indiana University Health
Influenza Incident Command
2018 to 2020
Indiana University Health
IP orientation for ICU residents
2018 to current
Indiana University School of
Medicine
Residency Applicant Inverviewer
2018 to current
Indiana Univeristy School of
Medicine
Faculty Awards Committee
2018 to current
Indiana University Health
Isolation 2.0 Curriculum Development
2019
Indiana University Health
MPCU CAUTI/C diff Harm pilot
2019 to current
Indiana University Health
Transplant CLABSI harm reduction QI
project
2019 to current
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 34 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 34 of 38

8
Indiana University Health
BMT C diff reduction QI project
2019 to current
Indiana University Health
The "Basics" Team for Harm Reduction
2019 to current
Indiana University Health
Augmented C diff response development
2019
Indiana University Health
Device Indication Standardization Project
2019
Indiana University School of
Medicine
Medical Response Team
2020 to current
Indiana University Health
COVID Incident Command
2020 to current
Indiana University Health
Diagnostic Stewardship System
Development
2020 to current
Indiana University Health
Epidural Foley Project with Surgery
2020

REGIONAL

Organization
Activity
Inclusive Dates
Indianapolis patient safety
coalition
Member
2017 to current
Orange Theory COVID Advisor
Advisor
2020 to current
College Park Church COVID
Advisor
Advisor
2020 to current

NATIONAL

Organization
Activity
Inclusive Dates
Infectious Disease Society of
America
Antibiotic Stewardship Education
Committee
2017 to current

INVITED PRESENTATIONS – SERVICE
LOCAL
Title
Organization
Date
Don’t trust the Pus University Hospital 9/27/2017
Brace for Impact: The Flu and You University Hospital 1/18/2018
Interview for Flu WTHR 1/9/2018
Interview for MRSA RTV6 11/3/2017
Interview for Flu WTHR 10/12/2017

1. http://app.criticalmention.com/app/#clip/view/32671017?token=2642c46b-6c16-444b-88e7-
f830ee2a1d45 (WISH)
2. http://wishtv.com/2018/03/22/flu-cases-declining-but-still-as-dangerous-doctors-say/ (WISH)
3. http://wishtv.com/2018/02/13/indiana-flu-deaths-nearly-seventeen-times-higher-than-this-time-
last-season/ (WISH)
4. http://wishtv.com/2018/02/13/a-chilling-look-at-this-years-flu-season/ (WISH)
5. https://www.theindychannel.com/news/local-news/indianapolis/indianas-244-flu-related-deaths-
include-3-kids-4-or-younger (WRTV)
6. http://app.criticalmention.com/app/#clip/view/32245731?token=f9de2a1d-7441-40b0-83c0-
9072090b0ccf (WTHR)
7. http://app.criticalmention.com/app/#clip/view/33752168?token=4df7120b-76f4-4dc9-b29d-
e0f54b00ba40 (WISH)
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 35 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 35 of 38

9
8. http://app.criticalmention.com/app/#clip/view/33764096?token=4df7120b-76f4-4dc9-b29d-
e0f54b00ba40 (WISH)
9. http://app.criticalmention.com/app/#clip/view/32671015?token=2642c46b-6c16-444b-88e7-
f830ee2a1d45 (WRTV)
10. http://indianapublicmedia.tumblr.com/post/172040087114/hospitals-lift-visitor-restrictions-as-
flu-season (WFIU)
Interview for Flu WTHR/NPR 10/18/2018
Interview for Chagas WTHR 6/201/2019

REGIONAL
Title
Organization
Date
Community-Acquired Pneumonia Union Hospital Terra Haute 1/17/2018

NATIONAL
Title
Organization
Date

INTERNATIONAL
Title
Organization
Date

PUBLICATIONS:

TEACHING
Refereed
Luther VP, Shnekendorf R, Abbo LM, Advani S, Armstrong WS, Barsoumian AE, Beeler CB,
Bystritsky R, Cherabuddi K, Cohen S, Hamilton KW, Ince D, Justo JA, Logan A, Lynch JB 3rd,
Nori P, Ohl CA, Patel PK, Pottinger PS, Schwartz BS, Stack C, Zhou Y. Antimicrobial
Stewardship Training for Infectious Diseases Fellows: Program Directors Identify a Curriculum
Need. Clin Infect Dis. 2018 Apr 16. doi: 10.1093/cid/ciy332.
Contribution- Curriculum development, manuscript editing

Non-refereed

RESEARCH/CREATIVE ACTIVITY
Refereed

Non-Refereed

SERVICE
Refereed

Chung, EK, Beeler, CB, Muloma, EW, Osterholzer, D, Damer, KM, Erdman, SM. Development
and implementation of a pharmacist-managed outpatient parenteral antimicrobial therapy
program. American Journal of Health-System Pharmacy. January 1, 2016 Vol. 73 no. 1 e24-
e33.
Contribution- Manuscript development, editing

Beeler C, Dbeibo L, Kelley K, Thatcher L, Webb D, Bah A, Monahan P, Fowler NR, Nicol S,
Judy-Malcolm A, Azar J. Assessing patient risk of central line-associated bacteremia via
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 36 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 36 of 38

10
machine learning. Am J Infect Control. 2018 Apr 13. pii: S0196-6553(18)30143-3. doi:
10.1016/j.ajic.2018.02.021.
Contribution- Project conception, implementation training, data collection, data analysis,
manuscript writing, editing

Azar J, Kelley K, Dunscomb J, Perkins A, Wang Y, Beeler C, Dbeibo L, Webb D, Stevens L,
Luektemey M, Kara, A, Nagy R, Solid CA, Boustani, M. Using the agile implementation model
to reduce central line-associated bloodstream infections. Am J Infect Control. 2019
Jan;47(1):33-37. Doi: 10.1016/j.ajic.2018.07.008.
Contribution- Manuscript editing

Dbeibo L, Kelley K, Beeler C, Kara A, Monahan P, Perkins AJ, Wang Y, Brinkman A,
Snyderman W, Hatfield N, Wrin J, Miller J, Webb D, Azar J. Achieving Clostridioides difficile
infection Health and Human Services 2020 goals: Using agile implementation to bring
evidence to the bedside. Infect Control Hosp Epidemiol. 2019. Dec 5:1-3. doi:
10.1017/ice.2019.337
Contribution- Manuscript editing

Beeler C, Kerley D, Davis C, Hazen D, Snyderman W, Lyons K, Sadowski J, Sweeney J,
Debibo L, Kelley K, Webb DH. Strategies for the successful implementation of disinfecting port
protectors to reduce CLABSI in a large tertiary care teaching hospital. Am J Infect Control.
2019 Dec;47(12): 1505-1507. doi: 10.1016/j.ajic.2019.05.016
Contribution- Project conception, implementation training, data collection, data analysis,
manuscript writing, editing

Dbeibo, L., Brinkman, A., Beeler, C., Fadel, W., Snyderman, W., Hatfield, N., Sadowski, J,
Wang Y, Kelley K, Webb D, Azar J, Kara, A. (2020). Utilizing a real-time discussion approach
to improve the appropriateness of Clostridioides difficile testing and the potential unintended
consequences of this strategy. Infection Control & Hospital Epidemiology, 41(10), 1215-1218.
doi:10.1017/ice.2020.276
Contribution- Manuscript editing, scripting review

Dbeibo, L., Brinkman, A., Beeler, C., Kelley, K., Fadel, W., Wang, Y., Snyderman, W, Hatfield
N, Sadowski J, Kara, A. (2020). Assessing the Efficacy and Unintended Consequences of
Utilizing a Behavioral Approach to Reduce Inappropriate Clostridioides difficile
Testing. Infection Control & Hospital Epidemiology, 41(S1), S58-S59. doi:10.1017/ice.2020.543
Contribution- Manuscript editing

Valinetz, Ethan MD; Beeler, Cole MD; Erdman, Sharon M. PharmD, FIDP. Outcomes of
Orthopedic Hardware-Related Infection Treated Via a Public Teaching Hospital Outpatient
Parenteral Antimicrobial Therapy Program, Infectious Diseases in Clinical Practice: December
28, 2020 - Volume Publish Ahead of Print - Issue -
Contribution- Case review, data analysis, resident mentoring, manuscript development and
editing

Gavin W, Campbell E, Zaidi S, Dbeibo L, Beeler C, Kuebler K, Abdel-Rahman A, Luetkemeyer
M, Kara A. Clinical characteristics, outcomes, and prognosticators in adult patients hospitalized
with COVID-19. Am J Infect Control. Volume 49, Issue 2, February 2021, Pages 158-165.
Contribution- Study Design, Manuscript editing

USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 37 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 37 of 38

11
Shannon Page, Dana Hazen, Kristen Kelley, Ranjeet Singh, Richard B. Rodgers, Brian Brewer,
Joshua Sadowski, Armisha Desai, Cole Beeler, Douglas Webb, Jose Azar, Lana Dbeibo,
Changing the culture of urine culturing: Utilizing Agile Implementation to improve diagnostic
stewardship in the ICU, American Journal of Infection Control, Volume 48, Issue 11, 2020,
Pages 1375-1380, ISSN 0196-6553, https://doi.org/10.1016/j.ajic.2020.01.022.
Contribution- Manuscript editing

Dbeibo, L., Kuebler, K., Keen, A., George, A., Kelley, K., Sadowski, J., Basham, L, Beeson T,
Schmidt CM, Beeler C, Webb, D. (2021). Assessment of a Universal Preprocedural Screening
Program for COVID-19. Infection Control & Hospital Epidemiology, 1-9.
doi:10.1017/ice.2021.40
Contribution- Manuscript editing

Barros, N, Sharfuddin, AA, Powelson, J, Yaqub M, Adebiyi O, Beeler C, Lutz A, Fridell
J. Rabbit anti‐thymocyte globulin administration to treat rejection in simultaneous pancreas and
kidney transplant recipients with recent COVID‐19 infection. Clin
Transplant. 2021; 35:e14149. https://doi.org/10.1111/ctr.14149
Contribution- Manuscript editing

Andrew M. Peseski, Mitchell McClean, Steven D. Green, Cole Beeler & Heiko
Konig (2021) Management of fever and neutropenia in the adult patient with acute myeloid
leukemia, Expert Review of Anti-infective Therapy, 19:3, 359-
378, DOI: 10.1080/14787210.2020.1820863
Contribution- Literature search, Joint presentation with Heme/Onc, Resident mentorship,
manuscript editing

Non-refereed

(Date)

(Signature of Candidate)

USDC IN/ND case 1:21-cv-00238-DRL-SLC document 21-1 filed 07/02/21 page 38 of 38
USDC IN/ND case 1:21-cv-00238-DRL-SLC document 31-16 filed 07/12/21 page 38 of 38

File and source

File: gov.uscourts.innd.107499.31.16.pdf
Size: 933,358 bytes
SHA-256: ae02e6f5d01bda1370fb23968963e3672a7971e6f18676340b364a929250cbc9
Our copy: gov.uscourts.innd.107499.31.16.pdf
Original: archive.org

Declaration of Cole Beeler, M.D. — Klaassen v. Indiana University

Record facts

Summary

Full text

File and source

Related records