Senator Jeff Wentworth
The Senate of
March 18, 1998
Mr. Robert D. Crider, Jr.
Dear Mr. Crider:
VIA FAX: 458-7624
RE: PROPOSED RULES FOR STATEWIDE
I strongly urge the Board of Health to adopt rules that make it as easy for parents to deny consent for inclusion in the immunization registry as it is for parents to consent to inclusion in the immunization registry.
That was certainly my intent when I voted for Senator Patterson's floor amendment to House Bill 3054.
I urge the Board to consider the following amendments to the proposed rules to accomplish that goal:
§100.3 Providers, Health Plans, and Insurance Companies
I would also like to add that §100.5 (c), which states that providers will forward to the department parental requests that their child's immunization data not be reported to the registry appears to conflict with §100.2 (a)(4), which places the burden of notifying the department onto the parents. The bill passed by the Texas Legislature inclusion no extra effort in order for parents to decline inclusion.
§100.5 (f) appears to mandate ("...providcrs must report the following information....") far more information than House Bill 3054 required. For example, I do not believe that the bill called for the collection of children's social security numbers or mothers' maiden names. This type of information would appear to add to the fears of those who are concerned with the right to privacy.
Thank you for this opportunity to express my concerns about the proposed rules.