Vaccination Status Reporting Regulation

Government has approved the Vaccination Status Reporting Regulation requiring parents or guardians to report the vaccination status of their school-age children.  This regulation comes into force on July 1 and public health units will begin implementation of the regulation in September of 2019.

Recent outbreaks of vaccine-preventable disease in BC have highlighted the importance of immunization coverage rates, particularly for children in the kindergarten to Grade 12 (K-12) school system.  Since the beginning of 2019, there have been 29 confirmed cases of measles among B.C. residents. In response to these measles cases, the Province launched a two-phase plan to increase immunization rates in B.C.

Phase one was a measles catch-up program, which launched in March and will continue until the end of June for K-12 students.  During the period April 1 to June 30, 2019, 27,747 doses of measles-containing vaccines have been administered by providers in health authorities to kindergarten to Grade 12 students. This is a preliminary total and will rise when all records are received by public health officials.

Phase two is the introduction of the Vaccination Status Reporting Regulation (Regulation) under the Public Health Act.  When the Regulation is enacted on July 1, 2019, every student from K to 12 in public and independent schools, and those who are home-schooled, will be expected to have their complete immunization records in the Provincial Immunization Registry (the Registry).

If your child received their immunizations from a public health nurse in B.C., the information is automatically entered into the Registry and a record in the system will exist.  If your child received any of their immunizations from a physician or pharmacist or out of province, the information about those immunizations may not have been entered into the Registry and a record may be absent or incomplete.

Why do we need vaccination status reporting? 

Mandatory reporting of student’s immunization status increases public health’s ability to respond during an outbreak, as it allows health officials to quickly identify those who are underimmunized and unimmunized.

It is also a prompt for parents to check and ensure immunizations for their children are up to date and provides public health officials another opportunity to connect with families about why immunization is important for the health and well-being of their children, as well as the community. 

What will happen after July 1?

Health Authorities will be reviewing immunization records starting in late August and then will contact only those parents/guardians or students with incomplete or missing information. Information will be provided on how to update their school age children’s immunization records and where to drop off the information. 

If you are not contacted by public health, it means your records are complete and no further action is required. In subsequent years, only those who are enrolling in B.C. schools for the first time (e.g., Kindergarten or students who are new to the province), will be required to provide this information.

How will students’ confidential immunization information be protected?

• Students’ confidential immunization information is protected under the British Columbia’s Freedom of Information and Protection of Privacy Act (FIPPA).  Health authorities must collect, use and disclose the information in accordance with FIPPA.  
• In compliance with FIPPA, health authorities have established security protocols to ensure only authorized public health staff can access, view, use and disclose confidential immunization information.  
• The Vaccine Status Reporting Regulation (Regulation) also includes a requirement to collect and store immunization records in a manner that ensures confidentiality and security until they are transmitted to health authorities.
• Health authorities, through public health staff, are required to ensure confidential information is securely stored, and if required, disposed in a manner that ensures confidentiality.
• In some health authorities, schools already distribute and collect immunization consent forms to facilitate immunization information flow between public health and parents to support existing school-based immunization programs (Kindergarten, and in Grade 6 and 9).
• School staff/teachers/administrators are not authorized to review a student’s immunization information.  School employees will not be contacting parents to ask for immunization information on behalf of the health authorities.
• School employees will not be reviewing students’ immunization information, nor will the schools establish a database of student’s immunization information.
• Public health staff currently ensures that all confidential information provided to parents through schools is provided in a sealed envelope. Parents returning information through the schools should ensure their provided information is also returned in a sealed envelope to protect their child’s privacy.
• Parents may also return confidential information directly to their local health authority/unit. 
• The plans for distribution and collection of immunization information for implementation of the Regulation are currently being developed by health authorities, the BC Centre for Disease Control, and the Ministries of Health and Education. 
• Details of how this information will be distributed and collected, and the measures taken to ensure privacy and confidentiality, will be publicly communicated closer to the start of the 2019/20 school year.

What do schools (employees/administrators) have to do?

• Currently, public health staff, program and privacy experts in the Ministries of Health and Education, health authorities, and the BC Centre for Disease Control are developing implementation protocol and processes for the Vaccination Status Reporting Regulation (Regulation).
• For now, there is no change in the role of the school with the implementation of this Regulation.
  • Schools and school districts will continue to provide the public health units with the class lists.
  • Schools are responsible to ensure that registered students have up to date demographic information recorded.
  • Schools will maintain current practice and continue to support public health with the distribution and collection of consent forms as part of the routine process for immunization clinics offered at schools in Kindergarten and Grade 6 and 9.

How will parents be informed about what they need to do?

• Public health staff from health authorities will be contacting parents only if their children have missing or incomplete immunization records. The role of schools in this process is under review with further details to be determined prior to commencement of the 2019/20 school year.
• Public health staff will provide directions to parents on how and where to submit their children’s immunization information.

What provincial legislation authorizes the collection and use of students’ immunization information?

• The collection and use of immunization information by public health officials is allowed and anticipated under the Public Health Act and associated regulations, including the new Vaccine Status Reporting Regulation (Regulation).
• The Office of the Information and Privacy Commissioner (OIPC) has reviewed the privacy and information sharing considerations of this Regulation with the Ministry of Health (MoH). The MoH will continue engagement with the OIPC to ensure privacy and information considerations are addressed, and changes applied if warranted.

What can you do now, before the new school year? 

• If you know your child’s immunizations and record are up to date, and you are not contacted by public health and asked to provide information, no further action is required.
• If you believe your child’s immunization is not complete or does not exist in the BC Registry, you will be contacted by public health.  You could prepare by doing the following:
  • Students who received their vaccines through a physician and for whom parents have misplaced their child’s records are encouraged to contact the physician’s office to receive a copy of their immunization record and to ensure the immunizations are up to date.
  • Students who received their vaccines outside BC are encouraged to get a copy of their immunization record from their original provider.

** Please Note: At present, children attending schools in First Nations communities (on-reserve) are excluded from this regulation until further notice.  

B.C. Ministry of Health News Release