The technical advisory group (TAG) to consider COVID-19 for inclusion in the state's list of required immunizations for child care and school entry (chapter 246-105 WAC) held its last business meeting on Thursday, Feb. 24.
Criteria Summary and Voting Results
TAG members considered (4) criteria from the Board’s Immunization Criteria document. They discussed and voted on criteria #3, criteria #7, criteria #8, and criteria #9.
- Criteria 3 is under the category of vaccine effectiveness. Members considered if the vaccine containing the antigen is cost effective from a societal perspective. The TAG voted that the criterion was not met, with a majority of members voting no or unsure. Most members expressed concern for the lack of data for school aged children, that gathering data in a systematic way to address racial inequities is and remains a challenge, and many concluded that there is still too much unknown information about the vaccine at this time.
- Criteria 7 is under the category of implementation. Members considered if the vaccine containing this antigen is acceptable to the medical community and the public. The TAG voted that the criterion was not met, with a majority of members voting no or unsure. Members generally found the vaccine acceptable to the medical community; however, there was uncertainty amongst members around the public acceptance, more specifically around a school requirement.
- Criteria 8 is under the category of implementation. Members considered if administration burdens of delivery and tracking of a vaccine containing this antigen are reasonable. The TAG voted that the criterion was not met, with an equal number of members voting yes and no and a significant number voting unsure. Most members expressed concern for a possible increased administrative burden on schools to confirm student vaccine status and process exemptions.
- Criteria 9 is under the category of implementation. Members considered if the burden of compliance for the vaccine containing this antigen is reasonable for the parent/caregiver. The TAG voted that the criterion was not met. Most members expressed concern that while the vaccine is generally accessible there are many barriers that still exist for compliance and there is a disproportionate impact on communities of color. Members were also concerned that there are new barriers unique to the vaccine that present a major burden for parents or caregivers.
Final TAG Recommendation
TAG members discussed and voted on a final recommendation for the Board. TAG members voted to not recommend adding the COVID-19 vaccine to the state’s list of required immunizations for school entry. The votes were 6 yes, 7 no, and 4 unsure.
- Non-supportive: Members expressed doubt about making a recommendation to the Board and stated concerns about unintended consequences of doing so. Members stated concerns about a lack of good data and not being comfortable with children possibly losing time away from school.
- Supportive: Members who voted to recommend adding COVID-19 vaccine expressed the TAG had an opportunity to help eradicate the virus. Other members stated that the vaccine ought to be added once it is fully licensed by the FDA and other members expressed the vaccine should be added to the school entry list in the future.
The Board will consider the TAG’s recommendation at its April 13 public meeting. The Board, at their discretion, may or may not approve the TAG’s recommendation. If the Board were to vote to move forward, then the Board would initiate rulemaking to consider adding the COVID-19 vaccine to the list of required childhood immunizations for school and day care entry. The TAG’s recommendation will not be considered at the Board’s March 9 public meeting.
The exemption allowances currently listed in the state’s immunizations law would be available for families and their children who choose not to get vaccinated against COVID-19. These exemptions include medical, religious, philosophical, or personal exemptions.
Background and Summary
The Board convened a technical advisory group (TAG) in coordination with the state Department of Health (DOH) to develop recommendations for the Board to use when considering whether to add COVID-19 vaccine to the rules setting immunization documentation requirements required for school and child care entry.
The TAG held its orientation meeting on Dec. 29, 2021, received an update from staff at the January 12, 2022 meeting on the preparation work done to that date, and held regular business meetings Feb. 10, 17, and 24. The Board received a briefing on the immunization criteria and process used to consider additions to chapter 246-105 WAC at the Oct. 2021 Board meeting. After discussion, Board members voted to direct staff to begin the process of convening a TAG, in coordination with the state Department of Health to assess the COVID-19 vaccine against the nine criteria and develop a recommendation for the Board.
The Board has authority under RCW 28A.210.140 to adopt rules establishing the procedural and substantive requirements for full immunization. Chapter 246-105 WAC governs the immunization of children in school and childcare against certain vaccine preventable diseases.