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NEW Required Documentation for All Students

May 31, 2011 (This article is out of date. Please refer to our more recent immunization articles.)

Private and Home Educators of CA and HSLDA
(Private and Home Educators is a program of Family Protection Ministries)

Some changes in the law go into effect this July 1, 2011, that all homeschooling parents and PSP directors will need to act on. These changes are the following:

(1) An additional Tdap immunization booster shot against whooping cough has been added to the list of immunizations required, unless exempted, for all students in 7th through 12th grades (including those who are being homeschooled under the private school option).

(2) There has been a change in documentation required for a student’s records kept by their school of enrollment if a student receives this immunization.

(3) There is a change in documentation required for a student’s records if the student does not receive this immunization either because the parents choose to have their child exempted with the Personal Beliefs Exemption, or if the student has received a medical exemption letter from a physician.

AB 354 was signed into law in September 2010. It requires that all students be vaccinated against whooping cough with the Tdap booster on or after their 7th birthday as a condition for being admitted or advanced to the 7th through the 12th grade beginning this July 1, 2011. All references to the term “student” in this article refer only to students being admitted or advanced to the 7th through the 12th grade.

Every public and private school in California, including those based in the home, continues to be required to maintain an up-to-date copy of a California School Immunization Record (form PM 286B – aka “Blue Card”) as a part of each student’s permanent school record (i.e., cumulative file – see Sections 49062 & 49068 of the Education Code). The PM 286B form is available from your local county health department or you can download it for printing at http://www.cdph.ca.gov/pubsforms/forms/CtrldForms/pm286b.pdf.

To implement AB 354, the California Department of Public Health (CDPH) has created two new forms, which are to be used to document either that the student has been immunized against whooping cough with a Tdap booster (i.e., Tetanus, Diphtheria, Pertussis) or that the student is exempted from this required Tdap immunization. There are two possible exemptions from this new requirement: (1) the parent has completed a “Personal Beliefs Exemption” form CDPH 8261 (1/11) for the student, or (2) a medical exemption letter for the student has been received and is signed by a physician.

Beginning with the upcoming 2011-2012 school year, which technically starts on July 1, 2011, for public schools, every student must have received the Tdap booster and have that immunization documented in their school’s student records (as described below). Additionally, proof of immunization provided by the physician’s or health clinic’s immunization record must be kept on file in the student’s permanent school record (cumulative file), unless exempted. If a student has not received the Tdap immunization, that student must have either the personal beliefs exemption or the medical exemption documented and on file in their school’s student records, as described below. The exemption forms and documentation are not to be mailed or delivered by the school administrator to any entity but are to be filed in the student’s records kept by the school of enrollment.

For subsequent school years, every student who is being advanced into the 7th grade is subject to the same requirements described above. Students who move into California and will be in any grade from the 7th through the 12th grade will also have to conform to these immunization requirements.

The current “PM 286B form (1/02)” does not have a space to document the Tdap immunization. In order to document the compliance status of the student to the Tdap booster requirement on the PM 286B, the California Department of Public Health has created a sticker, form PM 286 S, which is to be completed and placed on the upper left corner of the front of the existing PM 286B “Blue Card”, which should already be in the student’s file. The PM 286B form documents compliance with current immunization requirements for all students in public and private schools (in any grades K-12). On the new sticker, you will fill in information, including documenting either the immunization, or the Personal Beliefs Exemption, or the medical exemption. The Department has also created a separate “Personal Beliefs Exemption” form, CDPH 8261, which has the same function as the “Personal Beliefs Affidavit” on the back of the current PM 286B (“Blue card”), but is limited to the Tdap immunization. These new forms are necessary because the current PM 286B form does not list the new Tdap booster immunization requirement. To see samples of these items, see “Sample Forms” here.

Every parent with a child entering the 7th to the 12th grade will need to make a decision for his or her child to receive or not to receive this Tdap immunization booster.

The sticker(s), form PM 286 S, and the “Personal Beliefs Exemption Form(s),” CDPH 8261 (1/11), if applicable, must be requested from your local county health department. Only school administrators may request these items. The State Department of Public Health will not make these available online or by request. The California Department of Public Health has stated, “Schools should not try to produce their own versions of these forms or use other forms.” http://www.shotsforschool.org/faq.html

If your private school was established by you and composed of your family members, and you have at least one child who is entering any grade from the 7th through 12th, you will need to call your local county health department to request enough of the stickers (form PM 286 S) for all your children (students) in these grade levels. Additionally, if you do not want your child(ren) vaccinated with the Tdap booster, also request copies of the Personal Beliefs Exemption form, CDPH 8261, for each affected child. When you call, call as the administrator of your private school, not as a parent.

PSP (private school satellite program) administrators need to notify the parents in their program of the new requirement and exemption options, and find out how many Personal Beliefs Exemption forms are needed for each family. Administrators should request enough copies of the Tdap immunization stickers (form PM 286 S) for each student in their program required to receive the Tdap under this new law. PSP administrators should also request enough Personal Beliefs Exemption forms for parents who choose to not have their child(ren) receive this booster.

For those students enrolled in PSPs, it will be the school’s PSP administrator and not the parent who is responsible for getting the stickers and exemption forms and having the documentation up-to-date and filed for every student enrolled in their program. While not required by the state, it would be a good idea for parents to also have a copy of each of their children’s immunization records in case needed when seeking medical attention in certain situations.

Your county health department’s phone number will be in the county section of your phone book. Or, you can also find a listing of county health department phone numbers via a link on our website. When calling, tell them you are a private school administrator from (name of your school) and you need forms and stickers for complying with the new Tdap immunization requirements.

They should forward you on to the person in their immunization department that handles the stickers and exemption forms. In most cases there will only be one person in each county equipped to send these new sticker forms and Personal Beliefs Exemption forms to you. That person will need to know the name of your school and how many students you have between 7th and 12th grade. You will need enough stickers for every child required to receive the Tdap under this new law. In addition, be sure to specify the number of Personal Beliefs Exemption forms you need. They will not automatically send out the same number of Personal Beliefs Exemption forms as stickers for your “Blue Card.” Directions for completing these forms should be sent to you when they send the forms.

*Important Note – As of May 2011, the State is out of stickers for the blue cards, so you may not be able to obtain them from your county as soon as you request them. The State is scrambling to get more made which includes a bidding process for the printing and a bureaucratic system to go through in order to finally reach county administrators. Your county’s health department should inform you when you call if they are out of the stickers and hopefully when they might have them in.

If the forms are not available from your county’s health department, you as the school administrator will want to keep in touch with your county health department until the forms you need can be sent to you.

Once properly completed, the applicable documentation is required to be kept in each student’s permanent school record (cumulative file) as mentioned above. The appropriate form(s) should be on file for each student in your school by the time your school starts for the 2011-2012 school year. For many homeschoolers, that would be some time around this coming August or September.

We recommend that the county health department be your only source for either the Tdap sticker PM 286 S or the Personal Beliefs Exemption form CDPH 8261 (1/11). They are not available online as of May 2011 and we have been told that they do not plan putting them online. You should not try to produce your own version of these forms or use other forms. As mentioned above, the California Department of Public Health has stated, “Schools should not try to produce their own versions of these forms or use other forms.”

NOTE: We DO NOT recommend signing up with an Immunization Registry program such as CAIR, which would result in children’s private information being entered into a bureaucratic database vulnerable to being accessed.

If there should be any changes in these forms, such as for subsequent school years, or any other news regarding the Tdap or any other immunizations, we will update this information.

For further information on this new Tdap requirement, go the California Department of Public Health’s “Frequently Asked Tdap Requirement Questions for: Schools and Providers” at www.shotsforschool.org.

For information to help you make the important decision whether to have your 7th to 12th grade child(ren) vaccinated with the Tdap booster, we suggest that you look at the page, “To Vaccinate or Not to Vaccinate” on our website.

SUMMARY

Step-by-step instructions for New Tdap documentation requirements:

Note to single-family private homeschool: You are responsible to obtain and keep immunization documentation for each student in your homeschool. For students entering grades 7th–12th you are responsible for each of the 3 steps listed below prior to the beginning of school this fall.

Note to PSP Administrators – You are responsible for the following:
a. Notifying the parents of students entering grades 7th–12th in your school of the new immunization requirement and the two options for being exempted.
b. Obtaining and keeping immunization documentation for each student in your PSP.
c. Each of the 3 steps listed below prior to enrollment this fall.

3 Steps – What you need to do:

Step 1.
Every student entering 7th–12th must get the Tdap booster or be exempted. If the student is being vaccinated, document, in the cumulative file of the student, a copy of the immunization record from a doctor or health clinic stating the booster has been administered, specifying that the Tdap booster was given and the date.
If the student is being exempted, the parents must fill out form CDPH 8261 (Personal Beliefs Exemption) OR provide a letter from their doctor documenting a medical exemption.

Step 2.
Call (see list of phone numbers) your county department of health to request 2 forms: Tdap stickers (form PM 286 S), which every student between 7th and 12th grade is required to have, and exemption forms (CDPH 8261) for those students whose parents do not want them to receive the booster shot. These forms are not available online. Identify yourself as an administrator of a private school, NOT as a homeschool and NOT as a parent. Tell them the number of students you have between 7th and 12th grade and request the form PM 286 S (Tdap sticker) for each of them. For those families choosing to exempt their child from the Tdap immunization, also request form CDPH 8261 (Personal Beliefs Exemption form) for each student whose parents desire to exempt.

Step 3.
Keep a file of the forms. EVERY student’s file, grades 7th–12th, must have the Tdap sticker (PM 286 S) affixed to the student’s California School Immunization Record PM 286B (aka “Blue Card”). The proof of immunization or signed exemption documentation MUST be filed with the student’s “Blue Card”.

The PM 286B (aka “Blue Card”) is available for download at: http://www.cdph.ca.gov/programs/immunize/documents/pm286b.pdf. Images of these forms and a sample medical exemption letter can be found on our website.