FAQ About Back-To-School Vaccination Paperwork Requirements in WA
ICWA has been getting emails from parents receiving letters from their children’s schools about vaccination. A new “Rule” went into effect on August 1, requiring medically verified vaccination records rather than parent-submitted — but this rule is NOT retroactive.
We contacted the DOH and for answers to your most frequently asked questions:
Q: Do students enrolled before the 2020-21 school year now need to turn in medically verified records?
(https://www.doh.wa.gov/YouandYourFamily/Immunization/SchoolandChildCare/RuleChanges#q29104)
DOH Answer: Students who will continue to attend the same school or school district they attended prior to August 1, 2020, do not need to resubmit records. All new immunization records turned in on or after that date must be medically verified. New students in a school district must provide medically verified records showing they meet requirements to be allowed into school starting on August 1, 2020. Children attending a child care must turn in an updated medically verified CIS annually.
Q: Does a Certificate of Exemption (COE) expire? Does a COE need to be renewed annually?
(https://www.doh.wa.gov/CommunityandEnvironment/Schools/Immunization/CertificateFAQs#q27916)
DOH ANSWER: The only type of COE with an expiration date is a COE with a temporary medical exemption. The COE does not need to be renewed annually. Once a COE is filled out, it can be used for the length of the student’s Washington state school career, including school transfers. If parents request changes to the COE a new form must be completed.In your email, you also asked about records required for online school attendance. Attached is joint guidance from DOH and OSPI that addresses immunization requirements for remote learning during COVID-19. Please note that this guidance is just for the 2020-2021 school year.
What if I’ve lost my child’s records or my healthcare provider closed?
https://www.doh.wa.gov/YouandYourFamily/Immunization/SchoolandChildCare/RuleChanges#q29093
DOH ANSWER: The Centers for Disease Control and Prevention (CDC) recommends revaccination if a person has lost their records. Your child may also get a blood test to determine immunity for some diseases. Check with your child’s doctor or clinic to find out what they recommend. You may also check to see if your child has any records in the state registry by using the personal registry portal, MyIR (https://wa.myir.net/).
ICWA RESPONSE:
Vaccination is a medical intervention that comes with the risk of harm. While we may argue about the level of that risk, we all agree risks exist. Expecting parents to expose their already vaccinated children to a medical intervention unnecessarily, when not medically indicated, simply because of a paperwork rule change, is an unethical way to handle the change. And while ICWA does advocate for titer testing to avoid over-vaccination, we fully acknowledge that blood antibodies are not an ideal measure of immunity to viral infections. And titer results for pertussis, a bacterial infection, are not accepted in lieu vaccination records because there is no antibody correlate of protection. Antibodies to that vaccine do not prevent pertussis infection or colonization or transmission.
In every other avenue of medicine, individuals are asked to fill out medical histories and their word is accepted. Why are parents being doubted now? Could this transition time be made more family-friendly and ethically sound?
The inability to produce medical records is likely to be uncommon, and it is [our] hope that the DOH will come up with an ethical way of helping those parents who find themselves in this situation negotiate this new rule, keep their children in school, and not pressure them into taking the risks of revaccination when not medical indicated. Until DOH comes up with a reasonable plan we can share, ICWA will be ensuring all who come to us about it know about their vaccination exemption options. Vaccinating families using exemptions to prevent revaccination under this new rule is not ideal, and it skews the data, but it may be their only choice to protect their children from the risks of an intervention that it not necessary or medically indicated.
