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November 19, 1998 Mr. Robert D. Crider, Jr. Dear Mr. Crider: When I wrote you last on September 8th, I had to comment at length on matters of concern to me about how the Departments proposed rules were--in my view--thwarting the will of the Legislature relative to implementation of HB 3054. 1 must now commend you and the Department on the substantial and refreshing changes in the proposed rules which soon may be adopted. I briefly want to make two suggestions before offering my congratulations on a job well done. I still oppose grand fathering of all data that was inputted prior to September 1, 1997. and would further recommend that those households whose records were obtained in wake of the effective date of the legislation be sent consent forms and all data deleted if the consent form is not returned signed. Under the procedures which up to now have been used to gain consent for inputting data into the vaccination registry, few families may actually have been aware what they were signing off on. I would also suggest that the check-off box on the birth certificate be eliminated since the act of consenting to vaccination at birth has been construed by TDH to automatically provide consent for participation in the vaccination registry. The latter was intended to be presented ONLY as a VOLUNTARY opt-in decision, and thus it is inappropriate to bundle together consent for vaccination administration with consent for participation in the vaccination registry. We have an obligation to not violate a parents or childs privacy or ability to chose whether or not to divulge confidential material, and should be careful to nurture their and the publics trust by the manner in which we steward our compilation of vaccination registry data and handle such sensitive information. Thank you for attempting to make sure these items have been addressed in your proposed rules. Sincerely, |
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