May 29, 2013
Patti Segal Freeman
Minnesota Department of Health
625 Robert Street North, PO Box 64975
St. Paul, Minnesota 55164-0975
Dear Ms. Segal Freeman:
The Immunization Action Coalition, a national non-profit organization based in St. Paul, fully supports the proposed
changes that would modify current school and child care requirements to simplify administrative procedures.
The Coalition also fully supports the implementation of the four new requirements. The four are hepatitis A and
hepatitis B vaccination for children in child care or school-based early childhood programs, and Tdap and meningococcal
vaccination for students beginning in grade 7. These vaccines are important for the health and well-being of our youth, as
illustrated below.
Hepatitis B, a serious liver disease caused by a virus, can lead to cirrhosis or liver cancer. Most infants receive the
first vaccination as newborns; however, they need an additional two doses to be fully protected against the disease.
Because most people infected with the hepatitis B virus don’t have any symptoms, children of any age can be
exposed to an infected persons without knowing it. Infection can occur as a result of bites, scratches, or contact with
blood from an infected playmate or family member. The new requirement in the proposed rule would expand the
existing hepatitis B requirements, which are for children entering kindergarten, to include children in child care
facilities and similar settings.
Hepatitis A is another serious liver disease. The virus that causes hepatitis A is found mainly in the stool of infected
persons. It can spread in child care settings from an infected baby to another baby if caregivers do not wash their
hands between diaper changes. Vaccination with hepatitis A vaccine has been a national recommendation for all 1year-old children since 2006, and many states have incorporated it into their child care requirements. Minnesota
should do the same.
Public health officials are well aware of the increasing incidence of pertussis (whooping cough) in Minnesota. A
preliminary total of 4,485 cases were reported in 2012, the most in more than 50 years. In 1996, a state-mandated
tetanus-diphtheria requirement became effective for students in seventh grade. Since then, an enhanced vaccine,
containing the pertussis component, has become available. Its use is now a national recommendation for all
adolescents at ages 11 to 12. The proposed Tdap requirements for seventh grade students will help quell the surging
pertussis epidemic in Minnesota.
Meningococcal disease is caused by bacteria that infect the blood, brain, and spinal cord. Even with appropriate
treatment, 10 to 15 percent of people with meningococcal disease die. In 2005, following licensure of an improved
vaccine, national recommendations were issued for routine vaccination for all preteens at ages 11 or 12 years. Many
states have adopted this recommendation as part of their school immunization mandates. It’s time for Minnesota to
do the same to prevent the devastating consequences of meningococcal disease.
With the exception of strategies that ensure the safety of the nation’s water supply, no other national health strategy has
had such a tremendous impact on the reduction of disease and improvement of health as has immunization. For nearly 50
years, state public policy has called for the enactment of vaccination requirements for children in child care facilities and
schools through statute or rule. These immunization requirements are one of our most effective tools in preventing
vaccine-preventable disease among children, adolescents, and adults. We therefore encourage the adoption of the four new
requirements and the modification of existing requirements as outlined above.
Sincerely,
Deborah L. Wexler, M.D.
Executive Director
Diane C. Peterson
Associate Director for Immunization Projects
May 21, 2013
Edward Ehlinger, MD, Commissioner
Minnesota Department of Health
625 N. Robert St.
St. Paul, MN 55155-2538
RE: Publication of Notice of Intent to Adopt Proposed Changes to Minnesota’s School and Child
Care Immunization Law
Dear Commissioner Ehlinger:
On behalf of the Minnesota Medical Association (MMA), I am pleased to reiterate my strong
support for the Minnesota Department of Health’s (MDH) proposed changes that will modify
the Minnesota School and Child Care Immunization Law, consistent with recommendations set
forth by the Centers for Disease Control and Prevention’s Advisory Committee on
Immunization Practices (ACIP). Several changes have been made to the federal immunization
recommendations, and it is vital that Minnesota’s immunization rules reflect these new,
evidence-based recommendations.
As MDH approaches this final phase of the rulemaking process, the MMA wants to lend its
support for proposed rule changes that will help the many children, families, and caregivers
that receive protection as a result of routine vaccinations. It has been ten years since the last
revisions were made to the immunization rules, and it is important that Minnesota law reflect
changes made to immunization schedules, the addition of new vaccines, the clarification of
reporting requirements, and the inclusion of all school-based early childhood programs. Doing
so will ensure that children, schools, child care facilities and immunization providers in
Minnesota are in compliance with federal immunization recommendations.
By bringing Minnesota law in line with current federal immunization recommendations, MDH
is demonstrating a commitment to reducing the incidence of vaccine-preventable diseases.
These efforts will help protect the health of not only Minnesota children, but the health of all
Minnesotans, and the MMA fully supports these efforts.
Sincerely,
Daniel E. Maddox, MD
President