A common question that has come up as the CDC has granted Emergency Use Authorization (EUA) of the COVID vaccine for children ages 5 to 11 is related to vaccine requirements for school and childcare attendance. Given the interest, I thought it would be timely to provide the details about how and why a vaccine is added to the list of required vaccines, and the process that is followed to add a vaccine.
Arizona law, specifically A.R.S. 36-672, vests the authority to determine which vaccines are required for school attendance with the Arizona Department of Health Services, not with individual schools. This is a responsibility that the Department takes seriously. ADHS’ school and childcare attendance immunization rules are located in the Arizona Administrative Code, specifically in AAC R9-6 Article 7. Changes to these rules, including the addition of new vaccines to the list, would be required to go through the normal rulemaking process prior to being required for school attendance. The rulemaking process is set forth in statute and is important because it allows for a public process and the opportunity for public comment from all interested parties: parents, healthcare professionals, the education community, and everyday Arizonans.
New vaccines are typically considered for addition to the Arizona rules based on updated recommendations from CDC’s Advisory Committee on Immunization Practices (ACIP) after a vaccine has been given full approval by the federal Food and Drug Administration (FDA). If a new fully approved vaccine is added to CDC’s routine childhood immunization schedule or the childhood immunization schedule is updated to change the age or frequency of administration of fully approved vaccines for universal childhood immunization, ADHS considers adding these vaccines to the Arizona rules for school and/or childcare attendance. For example, a little over a decade ago ADHS updated the school vaccine rules to require the tetanus, diphtheria and pertussis (TDaP) and meningococcal vaccines for adolescents following recommendations by ACIP that added these vaccines to the routine childhood immunization schedule for this age group. Not all ACIP-recommended vaccines, such as the influenza vaccine, are included in the Arizona school immunization requirements. This could be due to a number of factors, including legislative requirements, vaccine effectiveness, and timing of when rules are open and when ACIP recommendations are updated.
None of the current COVID-19 vaccines for use in people under the age of 18 have gone through the full approval process and are currently only available under the EUA designation from the FDA. As such, those vaccines would not be considered for addition to the list of required vaccines promulgated by ADHS for school and childcare attendance at this time. Of note, ADHS has never added a vaccine to the schedule that only has an emergency use authorization.
As with all of our required vaccines for school and childcare attendance, exemptions are available for parents to exclude their children from the requirements. Exemption criteria are listed in the same section referenced above, AAC R9-6 Article 7, specifically R9-6-706.
The bottom line is that ADHS takes the vaccine requirements for school and childcare attendance very seriously. We take many deliberative steps to gain the public’s input and have oversight from the Governor’s Regulatory Review Council as a final evaluator before a vaccine can be added. And we never take away parental rights.
We encourage all parents to review the information from the FDA and CDC and consider vaccinating their children. For parents who do wish to get their children vaccinated under the EUA, the Department is committed to ensuring that vaccines are available to you. Please see azhealth.gov/COVID19Vaccines to find more information on how you can get your child vaccinated.