Testimony of Peg Devine to the BOE, November 21, 2019

I’m here to discuss some very serious problems regarding immunization compliance. Firstly, the district sent POSTCARDS via US mail on October 3rd  with the student’s name and statement, your child “is not in compliance with Pennsylvania State immunization law.” Had this information been sent in a sealed envelope I would not be concerned but to be sent as a POSTCARD it is careless disregard for students’ confidential medical information and I believe this is a FERPA violation. How can you assure parents that only persons with “legitimate educational interest” were able to read these postcards?

Secondly, I am deeply disturbed by the tampering of electronic student health records which occurred regarding immunization documentation.  On Friday, November 1st an email was sent by Karyn Lynch informing the certified school nurses that provisional dates would be “centrally entered” into the Student electronic health record. This tampering of medical records by unlicensed staff is positively unacceptable.

According to state regulations, these students are non-compliant. These parents provided no medical certificate. The state requires a specific immunization plan for a student which is to be filled out and signed by a physician, certified registered nurse practitioner or physician assistant and given to a school as proof that the student is scheduled to complete the required immunizations.

The email implied that a “field trip” plan would be in agreement with the State mandate, yet these provisional dates were entered WITHOUT parental consent for these so called “field trips.” This reckless “Plan” is deeply disturbing and shows no respect for the professionally licensed staff  who have been ignored throughout this process.  In addition, the email made NO to reference to the Parental Permission EH-80 form which is required for field trips. The EH-80 provides emergency contacts and health information which is essential to health care providers who are being asked to administer immunizations to teens without their parents or guardians being present.

We have been asking since last year to allow us to follow the state mandates and the problem has not been resolved. Just this afternoon we received a formal Health Alert notification from the health Department of a cluster of Pertussis at a school in Philadelphia. I am respectfully asking this board to step in and demand that the State Licensed Professionals be allowed to do our jobs as directed by state mandates and to document on electronic records without the tampering interference of non-licensed administrators.