Update on Connecticut’s School Immunization Requirements

On February 16, 2023, Connecticut’s Commissioner of Public Health (“Commissioner”) issued a memorandum to school nurse supervisors and school medical advisors regarding medical exemption reporting and in-process immunization requirements for Connecticut students.  

As we described in our prior post here in 2021, Connecticut significantly modified its law regarding exemptions from state immunization requirements.  These changes eliminated the state’s religious exemption from school immunization requirements, while still allowing certain students to continue to rely on existing and recognized religious exemptions under the law’s legacy clauses.  The revised law also addresses medical exemptions and students who are not yet fully immunized but are in the process of receiving required vaccinations.  The February 16th memorandum provides further guidance to schools regarding these changes and requirements.

Medical Exemptions from Statutory Immunization Requirements

Even as modified, Connecticut law continues to permit medical exemptions from certain immunizations, provided certain conditions are met.  In particular, the child (or the child’s parent or guardian) must present a certificate, in a form prescribed by the Commissioner of Public Health, from a physician, physician assistant or advanced practice registered nurse (collectively, “Healthcare Providers”) stating that in the opinion of the Healthcare Provider, immunization is medically contraindicated because of the child’s physical condition.

In accordance with the new law, the Connecticut Department of Public Health (“DPH”) created a Student Medical Exemption Certificate for Required Immunizations.  In its February 16th memorandum, the Commissioner announced that DPH has also created a secure, web-based portal to collect medical exemption information from each Healthcare Provider who provides a child with such certificate.  The memorandum further states that the child’s school must also continue to receive a copy of the form.

In-Process Immunization Requirements

Following the changes to the state’s school immunization law, questions remained as to how to address unvaccinated children who are now in the process of becoming compliant with state vaccination requirements.  Regarding “in-process” vaccination, the memorandum states that students whose initial immunizations have been given but for whom additional required immunizations are in process must submit the Healthcare Provider’s Certification of In Process Required School Immunizations from their Healthcare Provider, indicating that additional immunizations are in process according to guidelines and schedules specified by the Commissioner of Public Health.  The form states that Healthcare Providers must follow the Centers for Disease Control and Prevention catch-up schedule for the minimum spacing interval between doses and complete the administration of the additional required immunizations no later than thirty (30) days after the minimal interval time period has passed. 

For a particular subset of these students, the provider may submit a different form. Such declaration may be used only for a student who, prior to April 28, 2021, was (1) enrolled in a preschool program or other prekindergarten program, and (2) exempt from the state’s immunization requirements based on a statement submitted to the program that such immunizations would be contrary to the religious beliefs of the student or the student’s parent or guardian.  The memorandum further explains that the declaration form should be shared with the school the student attends. 

If you have questions about school immunization requirements, exemptions, and in-process vaccination schedules, please contact Dori Pagé Antonetti at dantonetti@goowin.com, Julie Fay at jfay@goodwin.com, Sarah Gleason at segleason@goodwin.com, or Jessica Richman Smith at jsmith@goodwin.com.

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