Please note: LCAR does not post documents to their website. We do not know whether there is an archive as to what gets submitted (but there should be).
In summary, our position was that Act 37 (2015-2016) rule making was insufficient, and moreover, the required parent educational material is still inadequate – an unresolved issue. Here is what we told the Vermont Legislative Committee on Administrative Rules in 2016.
Jennifer Stella –
View VCVC Testimony packet March 31, 2016 (delivered in hard copy to each person on committee). Additional in-person testimony – video not available – recording may be available thru Leg council – copy of material here
Sec. 4. 18 V.S.A. §1122 specifies that educational material must include, “information about the risks of adverse reactions.” However, as we discovered, the department revised already existing educational materials and removed information about risks. In this way, the Department is not fulfilling statutory requirements on provision of risk information per §1122 of the subchapter.
Dorian Yates – (view testimony file)
According to the DOH response #6, the Parent Education information, which is required by statute to contain information about risks, is being revised. It is unclear whether the information that appeared sometime on the DOH Website after March 1st, is still being revised or is the new version. In either case, the timing of the revisions was after the public hearing comment-period, so below are comments and concerns regarding the Parent Education information.
The Act states that anyone claiming a religious exemption “has reviewed evidence-based educational material provided by the Department regarding immunizations, including: Rule (i) “information about the risks of adverse reactions to immunization”
With regards to (i), the Parent Education information does not address the risks of adverse reactions to vaccines other than saying that, “results revealed that vaccines are not free from side effects or adverse events, but most are very rare or mild such as swelling at the injection site, slight fever and headache.”
Sandy Reider MD: (view testimony file)