Dear Members of the Public Health Committee, I oppose the removal of the religious exemption as proposed by HB-6423 and SB-568. In HB-6423, students with a religious exemption (RE) who are enrolled in seventh grade or higher by the effective date of the bill would be grandfathered, while children in sixth grade or below would be removed from school. The explanation given for this is that the exemption rates at the seventh grade checkpoint are typically lower than at the kindergarten checkpoint. Based on the data provided by the DPH on Friday night, Kindergarten RE rates decreased by .2% between 2019-2020 and 2018-2019 (2.3% from 2.5%) while seventh grade rates actually increased by .2% in the same timeframe (1.5% from 1.7%). For the 2019-20 school year, the CDC reports, “The national exemption rate remained low at 2.5%.” Using data provided on the Department of Public Health immunization surveys and the Department of Education’s student enrollment numbers (EdSight) for the 2019-2020 school year, the CT religious exemption rate for all schools was 1.5% - a full point lower than the already “low” national average despite CT requiring the most vaccines on our school schedule. One possible explanation for the higher rates in kindergarten is the flu shot mandate for children under 5 years old. Many students are still 4 when they start the school year because of our late cutoff for school registration. For their parents to deny the flu shot, just until they turned 5 when it would no longer be mandated, they would need an RE on file. Preschool data has not been included for the last two years, but in 2017-2018, two-thirds of all RE used in preschool were for the flu shot only (1097 for flu shot only, 510 RE, 1607 total). Eliminating the flu shot requirement for children under 5 who are enrolled in kindergarten or allowing a separate RE for the flu shot only as used in preschool/prekindergarten, would more accurately portray which students are up to date for the other vaccines on the school schedule. Another reason for an increase in religious exemptions at kindergarten is that vaccinations requirements don’t align with the school calendar. Most other states require children to turn 5 before or shortly after entering kindergarten, but CT has the latest cutoff in the nation of December 31. In addition to the flu shot, CT also requires the Hib and pneumococcal vaccines for students under 5. Students could be considered noncompliant or be required to submit an RE for the few short months until they have their fall birthday. Also, the CDC recommends the second dose of MMR between 4 and 6 years old - when most students start school. These children could be considered noncompliant as far as vaccination rates, but actually be within the recommended CDC timeframe to get the vaccine. The data supplied for kindergarten and seventh grade separately shows the rates for specific vaccines. Many schools, 58% of the 544 kindergartens and 61% of the 303 seventh grades with school data in fact, have a vaccination rate lower than the corresponding exemption rate. For kindergarten, 128 schools (23%) have rates that fall below the 95% herd immunity, but have less than 5% RE rates, and 39 of those have zero RE on file and for seventh grade 84 schools 28%) have rates that fall below the 95% herd immunity, but have less than 5% RE rates, and 45 of those have zero RE on file. These differences were described by the DPH as belonging to students with immunizations in progress and those who are noncompliant, with neither a catch-up schedule nor exemption on file with the school nurse. These surveys are meant to capture the school immunization rates, but they only explain the percentage of students using either a medical or religious exemption. This does not give an accurate picture of each school’s actual vaccination rates. If the goal is to maintain vaccination rates over 95%, the least restrictive way of accomplishing this is to focus on the students who have vaccinations in progress and those who are noncompliant. An additional flaw of the data is that the DPH does not release the total number of exemptions in use nor the religious or medical exemption rates for all schools. These numbers are only provided for new enterers at kindergarten and seventh grade. For the last two years, I have collated the DPH and Dept of Ed’s data to find those numbers. In 2018-2019 school year, I estimated there were 7801 religious exemptions in use – and the DPH testified that it was about 7800. This year I have estimated about 8400 religious exemptions for a rate of 1.5% for all schools and all grades. These numbers show an increase of about 600 religious exemptions from one year to the next or .1%. This increase would equate to one additional student using a religious exemption for every two public schools. I also testified about how pockets of lower vaccinations rates are a measuring artifact. The data once again shows that one child is a disproportionately larger percentage in small schools versus larger schools. On average, larger schools have low exemption rates, while smaller schools have higher exemption rates because one student with an RE makes a much greater impact in a small school. Let’s compare two schools that have 1 RE each: 1. The Early Childhood Center at Central Ave, Naugatuck, has 27 students. Technically their data shouldn’t have been released because there are fewer than 30 students. One student at that school counts for 4.1% of that school’s enrollment. 2. Hartford Public High School has 976 students. One student is .1% One student has a 4000% greater impact in this small school versus this larger. What about the largest school in CT, Danbury High School which has the highest enrollment at 3292 versus the smallest public school, Eagle Academy with 7 students? One student would have 47048% greater impact on the RE rate in the smallest public school versus the largest, but it is still only ONE child. 2019-2020 Number of Total Average Percent of State Percent School RE Schools Enrollment Enrollment Total Enrollment Impact of Percentage in of All per School & Cumulative % Single Rates Category Schools in in Category Exemption in Category Category 0.0-4.99% 1,201 549,094 457 96.76% 96.76% 0.22% 5.0-9.99% 64 14,865 232 2.62% 99.38% 0.43% 10.0-19.99% 25 3,038 122 0.54% 99.92% 0.82% 20% plus 6 480 80 0.08% 100.00% 1.25% 468% greater impact on TOTALS 1,296 567,477 small schools than larger ones I also analyzed the non-public school data as provided by the DPH, but there is no publicly available state database for private school enrollment data. Higher exemption rates are coming from non-public schools that fit into 3 categories: religious schools, Montessori/Waldorf/small schools or special educations schools. This is a logical expectation, as these types of schools attracted students who may have vaccine injury or our religoius. This bill: ● Aims to remove the religious exemption completely for all public and private K-12 schools, child care, institutions of higher education and child group care homes for children not yet enrolled in sixth grade. ● Grandfathers only those children who are enrolled in seventh grade and have an religious exemption on file. ● Gives children/students who previously used the religious exemption until Sept 1, 2022, to get the initial dose of any missed, age-appropriate vaccines and to create a catch-up schedule for any additional required doses. ● Requires children/students who are medically exempt from one or more of the vaccines on CT’s vaccination schedule to submit a new certificate, to be created by the Department of Public Health ● Establishes an advisory committee with access to CT WiZ - the CT state vaccination database, the authority to review whether children/students using the medical exemption should be required to meet other criteria and if the DPH should have any oversight on the usage of exemptions. ● Requires any adult, born after 1956, enrolling in higher education classes held on the campus of colleges, universities, academies, tech and vocational schools and seminaries, to have proof of receiving two doses of MMR, two doses of chickenpox and two doses of the meningitis vaccine (for students living on campus) unless they have a certificate from their medical provider that they have had a confirmed case of measles, mumps, rubella or chickenpox or their medical provider uses the new DPH certificate to state that it would not be advised to get those vaccines because of the student's health. …all because of data that is filled with inaccuracies and doesn’t prove that those with a religious exemption are even a risk. Thank you, Jessica, groton My research for the All Grades data will follow. The columns in grey were supplied by the Department of Public Health 2018-2019 School by School Immunization Survey. The blue columns are data from www.edsight.ct.gov and the private school data was looked up individually for each private school. The data was unavailable for the schools with * instead of numbers. School Name OfficialTown County School type Ex_Rel Ex_Med Ex_Tot # Students RE ME Total Andover Elementary School Andover Tolland Public 3.0% 1.0% 4.1% 195 5.94 1.98 7.92 Assumption Ansonia Ansonia New Haven Non-public 7.0% 0.0% 7.0% 200 14.05 0.00 14.05 Ansonia Middle School Ansonia New Haven Public 0.7% 0.0% 0.7% 356 2.43 0.00 2.43 Ansonia High School Ansonia New Haven Public 0.0% 0.0% 0.0% 513 0.00 0.00 0.00 Mead School Ansonia New Haven Public 0.7% 0.2% 0.8% 620 4.08 1.02 5.10 Prendergast School Ansonia New Haven Public 0.6% 0.0% 0.6% 639 4.02 0.00 4.02 Emmet O'Brien Technical High School Ansonia New Haven Public 1.7% 0.2% 1.9% 648 11.02 1.00 12.02 Ashford School Ashford Windham Public 3.5% 0.3% 3.8% 390 13.75 0.98 14.74 The Webb School in the Valley Avon Hartford Non-public * * * * * * * Talcott Mt.