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Dennis Bonnen March 19, 1998 Mr. Robert Crider, Jr., M.S., M.P.A. RE: New sections proposed under the Health and Safety Code, section 161.007, which requires the board to adopt rules to implement the immunization registry. Dear Mr. Crider, As the Department of Health considers the adoption of the proposed rules implementing the immunization registry created by House Bill 3054, 75th regular session, please make every effort to insure that parental rights are protected and that the confidentiality of the information included in the registry is upheld.Parents' right to choose whether to participate in the registry should be honored and clearly defined in the new sections. Parents should be informed of the registry by their health care provider and should have the right to decline participation at the time they are informed and in writing to the Department. Health care providers and insurance companies should be held to strict requirements regarding the collection and dissemination of the information and should be responsible for informing parents of their rights with regard to inclusion in the immunization registry. The Department should also respect the right parents to withdraw from the registry at any time. Additionally, any decision to withdraw from the registry should be honored in a prompt manner and all related information should he removed from the registry. With regards to the protection of the data itself, please insure that the proposed rules will maintain the integrity of the confidentiality of the records and that no record is released improperly or illegally. All information maintained in the registry should be subject to the Medical Practices Act. Please insure the proposed rules for the implementation of the immunization registry meet these requirements for the protection of parental rights and the maintenance of the confidentiality of the data collected. Sincerely, Dennis Bonnen |
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