Since pharmacists now provide some immunizations, has any consideration been given to listing licensed pharmacists, along with physicians, registered nurses, or health department officials as those who are authorized to give or verify immunizations given? 

The regulations as proposed may lead to confusion over exactly when the second dose of varicella, measles, or mumps vaccine is required.  A child may enter kindergarten prior to turning six years of age but should have these vaccines prior to attending school.  I suggest removing the "at four to six years of age or" in each section for those vaccines, simply stating "prior to entering kindergarten".

It is possible that the conditional enrollment period for hepatitis B vaccine as currently defined could be misinterpreted. It is only when more than 2 doses of hepatitis B vaccine are required that students should be allowed more than the usual 90 days to complete the missing vaccination series. As currently written, this could be interpreted to mean that 180 days would be allowed to complete vaccine series other than hepatitis B.

On behalf of the Virginia Nurses Association, the professional organization for Registered Nurses, I am writing in support of the revised regulations governing childhood vaccinations (12VAC 5 110). VNA would respectfully request that you include the term, “registered” in 12VAC 5-110-100 as follows in the next paragraph (in parentheses). We believe that the omission of “registered” is an inadvertent omission. Registered nurses are identified, along with physicians, as those health care professionals who are authorized to document the proof of vaccination administration.

12VAC5-110-100. Responsibilities of physicians and local health departments.

B. Documentary proof for out-of-state students. For a student transferring from an out-of-state school to a Virginia school, the admitting official may accept as documentary proof any immunization record for that student that is signed by a physician or (registered) nurse and which that contains the exact date (month/day/year) of administration of each of the required doses of vaccines when indicated andwhich that complies fully with the requirements prescribed under 12VAC5-110-70. Any immunization record which that does not contain the signature of a physician or a (registered) nurse and does not contain the month/day/year of administration of each of the required vaccine doses shall not be accepted by the admitting official as documentary proof of adequate immunization with the exception of immunization against Hib. Such a student's record shall be evaluated by an official of the local health department who shall determine if that student is adequately immunized in accordance with the provisions of 12VAC5-110-70. Should the local health department determine that such a student is not adequately immunized, that student shall be referred to his private physician or local health department for any required immunizations.

Thank you so much for your attention to this request. Do not hesitate to contact me at 804-282-1808 if you have questions.