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Department of State Health
Services
School
Immunization Compliance
www.ImmunizeTexas.com
Learning Objectives
At the end of this presentation, each participant will
be able to:
• Identify the source & authority for
immunization rules
• Interpret the differences between
immunization recommendations and
immunization requirements
• Differentiate between the two allowable
exclusions from compliance
Learning Objectives, Con’t.
At the end of this presentation, each
participant will be able to:
• List possible items that will be
considered for upcoming agency
rule review
• Identify recent legislation relating to
immunization requirements and
immunization awareness
Recommended or Required?
• Recommendations are for everyone
• Requirements are for children attending
child-care facilities or school
Source and Authority
• Recommendations are made by the CDC’s
Advisory Committee on Immunization
Practices (ACIP), which has representatives
of the American Academy of Pediatrics (AAP),
and the American Academy of Family
Practitioners (AAFP)
• Requirements are authorized by the Texas
Education Code and Human Resources Code
and are specified in 25 TAC §§97.61-72
(Texas Administrative Code)
Recommendation - DTaP
• DTaP – at 2 months, 4 months, 6
months, 15-18 months, and a booster at
4-6 years
• Final dose in series should be given
on/after 4 years of age
Tdap Recommendation
• Adolescents 11-12 years of age should
receive a single dose of Tdap instead of
Td*
• Adolescents 13-18 years who have not
have not received Tdap should receive
a single dose of Tdap as their catch-up
booster instead of Td*
*If
the person has completed the recommended childhood DTaP/DTP
vaccination series AND has not yet received a Td booster
Requirement-DTP/DTaP/Td
Upon entry into Kindergarten:
• Five doses of any combination DTaP/DTP
with one dose on or after 4th birthday
• Or, if the 4th dose was administered on or
after the fourth birthday, only four doses are
required.
DTaP/Polio
Calendar Month of 4th Birthday
• Students who received the 4th dose in
the calendar month of or prior to the 4th
birthday are in compliance IF:
– The 4th dose was administered prior to
August 1, 2004
– Enrolled in a grade (K-12) prior to August
1, 2004
7 years or older
• Students 7 years or older
– Three doses of any combination
Td/DT/DTP/DTaP vaccine (pertussis
vaccine is not required)
– One dose of tetanus-diphtheria
containing vaccine is required within
last ten years.
Frequently Asked Question
• Q: “Are children who received their 4
year immunizations in the month of or
prior to 4th birthday grandfathered
under the new law”?
• A: Yes. The rules now contain
language stating that students who
received the 4th dose in the calendar
month of or prior to the 4th birthday prior
to 8/1/04 be in compliance.
Recommendation - Polio
• All IPV schedule – at 2 months, 4
months, 6-18 months, and a booster at
4-6 years
• OPV acceptable only in special
circumstances
– Unvaccinated child traveling to polioendemic area in < 4 weeks
– Parents refuse additional injections
(3rd and 4th dose only)
Requirement - Polio
• Grades K-12:
– Upon entry into Kg, 4 doses
of IPV, one of which has to be
on/after 4th birthday;
–3 doses okay if the third dose
was given on/after 4th birthday
Frequently Asked Question
• Q: “On or after the 4th birthday”– is
there any flexibility?
• A: Yes. A dose of DTP or polio vaccine
required “on or after the 4th birthday”
may have been received up to four days
before the 4th birthday. And, if the dose
was received prior to 8/1/04, the student
is in compliance.
Recommendation-Hepatitis A
• Statewide routine recommendation for
children 1 – 18 years of age
• Special recommendation for areas
where hepatitis A incidence has
exceeded 10 cases per 100,000 on
average over a 10 year period
Hepatitis A Requirement
• Required for K-3 grade in areas where
hepatitis A incidence has exceeded 10
cases per 100,000 on average over a
10 year period
• Notification will be made by August 1 of
each year
• Effective by August 1 of the next year
• No counties added since 2005
Hepatitis A Requirement
• 2 doses on or after 2nd birthday
• Required for students attending
Kindergarten (K) through third grade in
designated counties
• Pre-K
– Statewide requirement (HB 1316 79th session)
– Verification of 2nd dose not required for
kindergarten entry unless the school is located
in one of the 40 designated counties
Counties Requiring Hepatitis A for Kg Entry
Counties that require hepatitis A vaccine
for entry into school or child-care:
Newly added counties as of December 2003
**Requirement effective August 1, 2005
Recommendation - Varicella
• All children <13 years of age should be administered routinely
two doses of varicella-containing vaccine, with the first dose
administered at 12-15 months of age and the second dose at 46 years of age (i.e., before a child enters kindergarten or first
grade)
• A second dose catch-up varicella vaccination is
recommended for children, adolescents, and adults who
previously had received one dose, to improve individual
protection against varicella and for more rapid impact on school
outbreaks
• The ACIP recommends that all people ≥13 years of age without
evidence of immunity be vaccinated with two doses of varicella
vaccine at an interval of 4-8 weeks
Reliable Varicella History
•
•
•
•
Written statement from a parent or guardian
Written statement from a physician
Written statement from a school nurse
Serologic test result
*The acceptable evidence of immunity has not
changed per the 2006 ACIP recommendation
Requirement - Varicella
• One dose on or after 1st birthday for
students in grades 1-12
• Two doses if first dose of vaccine given
at 13 years of age or older.
Recommendation - Hepatitis B
• At birth, 1-2 months, and 6-18 months
OR 1-2 months, 4 months, and 6-18
months
Requirement - Hepatitis B
• Three doses are required for students in
grades K-12
Two-Dose Hepatitis B Vaccine
•
•
•
•
Approved only for 11-15 year olds
2 (1.0 ml) doses given 4-6 months apart
1.0 ml Merck dose must be documented
Children and adolescents who have begun
vaccination with the three-dose series should
complete the three-dose series
• If it is not clear which dose an adolescent was
administered at the start of a series, the series
should be completed with the three-dose
schedule
Recommendation - MMR
• MMR at 12-15 months and 4-6 years
• First MMR should not be administered
before 12 months of age
Requirement – MMR/Measles
• Two doses of a measles-containing
vaccine with the first dose on or after
the first birthday; second dose by age 5
or entry into kindergarten.
Frequently Asked Question
• Q: “On or after the first birthday” is
there any flexibility?
• A: Yes. Up to four days prior to first
birthday. Doses administered prior to
September 1, 1990 may have been
administered in the calendar month of
the first birthday.
Provisional Enrollment Opinion
Rendered by Attorney General
(GA-0178)
• DSHS correctly interprets statutes
• DSHS provisional rules are enforceable
• A child may be denied school admission if the child is
not immunized, does not qualify for one of the
statutory exemptions, or does not qualify for
provisional admission
• DSHS, and not TEA, has statutory authority to adopt
rules on provisional school admission based upon
immunization status
Frequently Asked Question
• Q: “Are there any exceptions to
compliance?”
• A: Yes. Children and students may be
excluded from compliance if a medical
contraindication to vaccination exists,
for reasons of conscience, including a
religious belief, or if they are on active
duty status in the United States Military.
Frequently Asked Question
• Q: “How are Medical Contraindications
documented?”
• A: Medical contraindications must be
signed by an MD or DO licensed to
practice in the U.S. The statement
should indicate that it is the physician’s
opinion that the required immunization
would be injurious to the health and well
being of the child/student or a family
household member.
Frequently Asked Question
• Q: “What needs to be included in the
Medical exemption?”
– Must specify the specific vaccination
contraindicated
– Unless a lifelong condition is
specified, it is valid for one year from
date signed and must be renewed
annually
– Does not have to be notarized
Conscientious Exemption
• Allows exemption for reasons of
conscience, including a religious belief
• Applies to child-care facilities,
elementary or secondary schools and
institutions of higher education
• Student may be excluded in times of
emergency or epidemic
• Requires affidavit
Conscientious Exemption
– Requires written requests for affidavit,
including facsimiles
– Requires full name and date of birth
of child
– Allows request for up to five forms per
child
– Allows exemption for one or more
vaccines
– Affidavit form is valid for two years
Frequently Asked Question
• Q: “Can an existing exemption form be
modified to include newly added
vaccine requirements ?”
• A: No. Children and students wishing
to claim an exemption for reasons of
conscience, including a religious belief
must submit another exemption form to
the school.
Frequently Asked Question
• Q: “Can a student have two exemption
forms filed simultaneously”?
• A: Yes. Both forms are valid.
Conscientious Exemption
Requests
Current Data on Affidavit Requests
(as of dd/mm/yyyy):
• Number of forms sent out:
• Number of requests received:
• Number of children:
On the Horizon…
• Required 4-year review of current rules
will begin Summer 2007
• Workgroups will be formed to review
proposals for new requirements
– July to August
• Proposed Rule timeline
– Initial Proposal to DSHS Council, Fall 2007
– Final Adoption sometime in 2008
On the Horizon…
• Vaccine requirements to be proposed (earliest adoption for SY 08-09):
– 2 doses of MMR at kindergarten entry
– 2nd varicella dose at kindergarten entry
– Tdap for a certain grade level (7th)
replacing Td 10 years since last dose
On the Horizon…
• Nothing is FINAL—still in the early
phases
– The department will follow standard rule
procedure at the time of the official
proposal
– All stakeholders will be given opportunity to
provide input on all proposed rules via the
Texas Register commenting period
2007 Legislative Session
Summary of Legislation
Bills Signed into Law
• HB 1059
– Requires each ISD with internet access to
post DSHS immunization
requirements/recommendations, flu
information, flu clinic locations, and
information on how to request a
conscientious exemption
Summary of Legislation
Bills Signed into Law
• HB 3184 (Relates to child-care facilities)
– Requires DSHS to publish flu awareness
information on its website
– Requires DSHS to work with Family &
Protective Services to ensure flu
awareness information is distributed to
parents in August & September of each
year
Summary of Legislation
Other Bills Passed
• HB 1098
– No HPV requirement for 6th grade girls
• HB 1379
– HPV awareness
Summary of Legislation
Please contact DSHS Immunization
Branch, Austin for further information on
the implementation of adopted bills
Contact Information:
Monica Gamez
800.252.9152
Who Do I Contact
For More Information on
Immunization Requirements?
Ana Ivette Nunez
Department of State Health Services
Region (11) Immunization Branch
(956) 423-0130
[email protected]
QUESTIONS?
www.ImmunizeTexas.com