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SB 277 is being promoted using inaccurate data. This report examines the data gaps and misrepresentations and offers suggestions improve the accuracy of vaccination coverage measurement and the effect of Personal Belief Exemptions. See also https://www.scribd.com/doc/260453836/CA-SB277-Corrections ; https://www.scribd.com/doc/262966975/OPPOSE-CA-SB277-FRED-Simulation-Analysis ; https://www.scribd.com/doc/263329574/Oppose-CA-SB277-MMRV-Seizure-HCP-Injury-Reports-to-Federal-VAERS ;
Titolo originale
Oppose SB277 California Immunization Information Accuracy Analysis and Recommendations for Improvement to Eliminate “Dangerous Pockets”
SB 277 is being promoted using inaccurate data. This report examines the data gaps and misrepresentations and offers suggestions improve the accuracy of vaccination coverage measurement and the effect of Personal Belief Exemptions. See also https://www.scribd.com/doc/260453836/CA-SB277-Corrections ; https://www.scribd.com/doc/262966975/OPPOSE-CA-SB277-FRED-Simulation-Analysis ; https://www.scribd.com/doc/263329574/Oppose-CA-SB277-MMRV-Seizure-HCP-Injury-Reports-to-Federal-VAERS ;
SB 277 is being promoted using inaccurate data. This report examines the data gaps and misrepresentations and offers suggestions improve the accuracy of vaccination coverage measurement and the effect of Personal Belief Exemptions. See also https://www.scribd.com/doc/260453836/CA-SB277-Corrections ; https://www.scribd.com/doc/262966975/OPPOSE-CA-SB277-FRED-Simulation-Analysis ; https://www.scribd.com/doc/263329574/Oppose-CA-SB277-MMRV-Seizure-HCP-Injury-Reports-to-Federal-VAERS ;
California Immunization Information Accuracy Analysis and
Recommendations for Improvement to
Eliminate Dangerous Pockets In researching SB277 it has become apparent that California Department of Health Vaccination Coverage and Personal Belief Exemption reporting policies leave gaps and incomplete data regarding vaccination coverage and the effect of Personal Belief Exemptions. These policies result in the under measurement of vaccination coverage, and over measurement of the impact of Personal Belief Exemptions. These Policies, combined with using percentages to measure inappropriately small groups actually creates Dangerous Pockets- it does not identify them. Accurate data is critical when contemplating restricting a constitutionally guaranteed education based on interpretations of current vaccination coverage rates and exemption use.
There are 4 areas that need to be addressed.
1) Age of measurement 2) Complete inclusion of PBE holder vaccination records 3) Institution of a point system in place of percentages for PBE measurement 4) Ban use of percentage in unrepresentatively small populations Current System California currently requires 16 injections for Kindergarten enrollment. 4 Polio, 5 DTaP, 2 MMR, 3 Hepatitis B, & 2 Chicken Pox injections. CDPH currently reports at K enrollment the vaccination coverage of the incoming class in the Fall, before the school year is complete. A student may enroll with a complete CIS- Certificate of Immunization Status for all 16 injections. Conditional Entry is granted to students who are a) in the process of completing one or more of the injection series, or b) those who have been vaccinated but cannot provide adequate documentation. Children who are opting out of any of the 16 required injections can also meet the requirement by providing a COE- Certificate of Exemption, which can be either Medical or Personal Belief. In comparing the California system to other states we have identified timing issues and several data collection gaps which need to be resolved to provide an accurate measure of the vaccination coverage of California schools.
California Immunization Information Accuracy Analysis and
Recommendations for Improvement to Eliminate Dangerous Pockets 1) Age of Measurement- Move to First Grade / or Add a First Grade Report Kindergarten spans the 2nd MMR Dose recommendation age range CDPH currently assesses vaccination coverage at Kindergarten. This is problematic for several reasons. First, California Kindergartens accept children at age 5. The second MMR dose is scheduled during a 2 year window, age 4 to 6. Therefore a child under medical care in a practice where the Physician waits until the 6th birthday will be fully compliant with vaccination medical guidelines, yet require a Conditional Entry, or use a Personal Belief Exemption to meet California enrollment requirements because Kindergarten children enroll during the administration window, and not after this vaccine is medically scheduled. Measuring 1st grade will significantly reduce Conditional Entry students & increase vaccination rate measurement A child who has never been in a State Licensed Daycare of Pre-school prior to Kindergarten admission will not have been required to provide documentation of vaccination status. The bulk of the pediatric schedule is administered 0-24 months, so for some children it will have been years between the receipt of the vaccines and the need to document them. The final doses of Polio, DTaP both require receipt after age 4, as well as the MMR discussed above. They can all also still be in process at the beginning of the Kindergarten enrollment year depending on a families particular situation. Moving or adding a First Grade measurement report will provide a more accurate assessment. Up until 2011 CDPH performed a Selective Review every Spring, to follow up on the progress of the Kindergarten classes in providing paperwork and receiving missing doses. The results of the Selective Reviews consistently show the Conditional Entry rate dropping as much as , and vaccination rates increasing as much as 2% between the Fall reports close and the Spring review. The Selective Reviews are archived here: https://www.cdph.ca.gov/programs/immunize/Pages/ImmunizationLevels.aspx
California Immunization Information Accuracy Analysis and
Recommendations for Improvement to Eliminate Dangerous Pockets 2) Complete Inclusion of PBE Vaccination Records Currently CDPH disregards the entire vaccination record of any student using a PBE. This effectively classifies a student who may be exempting from only Chicken Pox, or Hepatitis B, as completely unvaccinated. Neither the student, class, school, district, nor state gets credit for any of the vaccines that have been received. This is critical information to understand the actual impact of PBE on California Vaccination Coverage. Not counting the received vaccines reduces the overall vaccination rates, and also makes a risk assessment impossible to perform because we do no not know the vaccination status of PBE students. We know from many sources that very few students are complete exemptors. In fact CDPH acknowledges this in their reports Individual antigen status is unavailable for students with PBEs. Therefore, individual antigen immunization coverage may be underestimated; anecdotal evidence suggests a small percentage of students may have some but not all required immunizations. The CDC notes that less than 1% of US children have received no vaccines. Reporting the received vaccines of PBE would be a simple, procedural change only because the CDPH is already tracking received and missing vaccinations of the Conditional Entrants. This is a policy change, and is done is many states, for example Washington and Oregon. 4.1% of Washington K-12 children have a Philosophical or Personal Belief Exemption on file. However, Washington tracks their usage by vaccine and no vaccine is exempted greater than 3.2% (range 2.6% -3.2%). This is a clear indication that parents are being thoughtful and not recklessly abandoning the program altogether, but simply tailoring a one size fits all schedule to their individual situation. It also provides a more accurate measure of the effect on exemptions. This is especially important in the smaller populations. On Shaw Island in the Puget Sound is one of Washingtons worst school districts with a stunning 20% plus PBE exemption rate, but because WA tracks all completed series the actual situation is not as dire as one would think. The Kindergarten has only 14 students, so each student counts as 7+% of the total. In looking at the school by vaccines exempted 13 of the 14 students have complete Polio, DTaP, and MMR series, and 12 of 14 are complete for Hepatitis B and Chicken Pox. Without individual vaccine tracking this district we would not have an accurate risk analysis. Instead we see that only 1 child is exempted from Polio, DTaP, and MMR, and only 2 from Chicken Pox and Hepatitis B. Does this sound like a powder keg of infection risk, compared to calling it a 20% Plus Exempted School?
California Immunization Information Accuracy Analysis and
Recommendations for Improvement to Eliminate Dangerous Pockets Considering that Californias total PBE is only 2.54% and dropping, using a ratio to comparable to Washington States of PBE total to exemption by vaccine, it is very likely that no vaccine on the California schedule is exempted higher than 1.7%. An Ideal 100% rate - 1.7% actual PBE usage by vaccine = 98.3% - well above desired levels.
3) Institution of a Point system to measure PB Exemption status
Along with fully tracking vaccination status a point system should be implemented which would give credit for every received injection of the 16 required. Currently, a student who has all vaccines except the final, 2nd Chicken Pox dose is measured as 100% Exempt, even though he is actually only 1/16th exempt, or actually 93.75% vaccinated. A point system would alleviate this misinterpretation that every exemption equals a completely unvaccinated child. Under the current system a private school where all of the students have all vaccines except Chicken Pox would measure as 100% exempt, even though they have all the rest of the requirements met. Tracking the received vaccines will help the accuracy and the point system will hone in further. Example- in a 20 student Kindergarten there are a potential 320 injections (20 x 16 injections per student). Under the current system a single student using a PBE would give the class a 5% PBE rate, (1 student equaling 5% of the class). If 2 students in this school are fully exempt from Chicken Pox but has all other requirements, and one uses an exemption to opt out of only the 5th DTaP, and one only the 2nd MMR dose, under the current system this school would be measured with a 20% Exemption Rate (4 x 5%=20%). Does this accurately represent the vaccination status and potential risk of this class? Instead, under a point system, this class would get a 98.22% positive vaccination rate, missing only 6 of 320 injections / points.
California Immunization Information Accuracy Analysis and
Recommendations for Improvement to Eliminate Dangerous Pockets 4) Ban Percentage use in small populations This is very inaccurate and misleading. We do not allow it for many tests score reports and other measurements where an individual is overrepresented, it should not be allowed for PBE reporting, either. The average school in California has 80 Kindergartners. One student then already counts as more than 1% when exemptions are calculated as all or nothing (100 divided by 80 =1.25%). A Kindergarten with 3 young students who turned 5 only in time for the age cutoff and still waiting for their 2nd MMR; 2 families who cannot provide Physician documentation of previous Chicken Pox infection because they have moved recently, or didnt take the child in because it was a mild case; and 2 families who exempt from the Hepatitis B vaccine because it is a blood borne infection would give the school an 8.75% Personal Belief Exemption Rate, (7 x 1.25%), yet nowhere near that percentage of students is completely unvaccinated. As a grade they are missing only 13 of the 1280 injections for complete coverage, or 98.99% compliant with requirements.
This analysis demonstrates that Dangerous Pockets are a measuring artifact of
CDPH Policies, not a true representation of risk to California school children and citizens. These policies need to be updated so that a proper assessment of the actual vaccination status and effect of Personal Belief Exemptions can be presented to the California State Senate and Assembly. Current legislation should be put on hold until these changes are Implemented and reported.