I am writing to voice my request and sincere hope that the board will mandate vaccines for all school employees, with only medical exemptions allowed. Vaccines are already required for all state employees. In addition, vaccines should be required for all students for whom the vaccine has been fully approved, just as many other vaccines are mandated.

My 10th grade daughter and all other kids have sacrificed much over the past 18 months. They only have one childhood. They are finally back to in person school, but we are already seeing constant disruptions to education for far too many due to infections, possible infections based on symptoms, and mandatory quarantines.

My daughter and all other students should have a right to be able to attend school without being unnecessarily put at risk by other students and teachers who refuse to be vaccinated, and without constant disruptions to their education. And it sure would be great for them to be able to go to school without masks and without worrying about lunch and other unmasked times, as well as overcrowded busses. The irrational minority should not be dictating the public health policy for VA or the schools.

Upon publication of the Notice of Petition in the Virginia Register of Regulations, and upon completion of the 21-day public comment period, VDH will make a determination - within 90 days of the close of the public comment period - as to whether or not to grant the petition.

On September 1, 2021, the Virginia Department of Health (VDH) posted a Petition for Rulemaking (Petition) to Town Hall that was received from a resident of Virginia. The Petition contained two requests: 1) mandate vaccines for all school employees, with only medical exemptions allowed and 2) mandate the vaccine for all students for whom the vaccine has been fully approved. The Petition was posted for a 21 day public comment period and received 15,308 comments. The summary of those comments can be found below.

Multiple factors influence decisions to require immunizations for school attendance including ACIP recommendations, fiscal considerations, feasibility of implementing the requirement(s), and administrative burdens that may be associated with such requirements.

With regard to the request to mandate vaccines for school employees, VDH does not have clear statutory authority to promulgate regulations for this population.

With regard to a mandate for students, § 32.1-46 of the Code of Virginia clearly provides statutory authority and VDH already promulgates the Regulations for the Immunization of School Children. However, VDH does not have statutory authority to remove the religious exemption.

At this time, all vaccines required by the Regulations for the Immunization of School Children are in alignment with recommendations from ACIP, CDC, AAP, and AAFP with the exception of influenza and COVID-19. VDH has determined that requiring influenza vaccine annually for all children for daycare and/or school attendance would have significant costs to VDH, the Virginia Department of Medical Assistance Services and school systems and daycares. It would also be complex to implement a requirement for school attendance because the new annual vaccine typically does not become available until late August or September, coinciding with the start of the school year. COVID-19 has been added to the CDC immunization schedule webpage but not yet added to Table 1, Recommended Child and Adolescent Immunization Schedule for ages 18 years or younger, United States, 2021.

With respect to the Petition, in light of the lack of clear statutory authority to implement vaccine mandates for school employees No Action is being taken as it relates to vaccine mandates school employees.

Also with respect to the Petition, given the continued administrative, logistical, and financial burdens related to influenza, and the COVID-19 vaccine not yet being added to the Adolescent Immunization Schedule for ages 18 years or younger, No Action is being taken as it relates to vaccine mandates for students.