Policy 203 – Immunizations & Communicable Diseases

On September 12, the UCFSD School Board will again discuss Policy 203, which outlines the District’s policy on Immunizations and Communicable Diseases.  This is an important policy of great interest to many in our district, given the events of the last two years.  I am grateful for the residents who have voiced their concerns about the policy and who have expressed an interest in the Board’s revisions.

To recap where we are in the revision process:

  • Policy 203 was last revised in August 2021, during the pandemic
  • In light of recent experience, court decisions, and widespread efforts to return to pre-pandemic protocols, the board revisited the policy in May 2022 (prior to my appointment in June) and planned to approve the policy in July 2022
  • Last month, the revisions were sent back to committee in light of questions that arose from board members, including myself, and from community members

In my view, there are three problems with the July 2022 version of Policy 203 that was proposed:

  1. The ‘authority’ section does not clearly articulate that UCF’s authority derives from State Regulations and legally-binding orders (not ‘guidance’) from State and County health departments
  2. The policy does not articulate with enough clarity the exemptions that are available
  3. The policy inappropriately elevates the COVID Health and Safety plan to be district policy

To address each of these problems, I think we should make the following changes to Policy 203:

  1. State that the authority for the policy is the School Code and legally binding orders from Federal, State, and Local agencies.
    • The requirements of Policy 203 come directly from the School Code (Title 28 Chapter 23.81-87)
      • Because the regulation is intended to prevent the spread of disease across the commonwealth, the requirements of the policy apply to all schools in the commonwealth, including public, private, parochial, and home-based
      • To prevent the spread of specific diseases, the state has mandated a consistent set of vaccinations and disease prevention practices. Therefore under normal circumstances there isn’t a role for the district to exercise local discretion or to deviate from what the state has mandated.
      • By explicitly referencing the school code as our primary authority, the Board will make it very clear that our intent is to adhere to what the State requires in the school code and any other legally binding orders that may be issued during an outbreak … nothing more and nothing less
  2. Explicitly include the School Code’s language on moral and ethical exemptions to immunizations.
    • The School Code Title 28 Chapter 23.84 clearly provides for an exemption “on the basis of a strong moral or ethical belief, which is similar in nature to a religious belief.”
    • There are residents in our district who object to vaccines based on strongly-held moral or ethical values that are not a product of religious belief, but are held with a similar intensity and seriousness of conviction
    • While individual citizens might like to see a different threshold (tighter or looser) for exemption, we are obligated follow the law and regulations as written 
    • Therefore, we should provide clarity and precision by utilizing the exact wording of the school code: “on the basis of a strong moral or ethical conviction similar to a religious belief”
  3. Remove the Health and Safety Plan (HSP) from Policy 203.
    • The stated purpose of the HSP was to enable the District to safely reopen schools, while supporting students and staff, providing an excellent educational experience, and helping end the pandemic
    • There are presently no mandatory requirements of parents/students contained in the current HSP, and there are no enforcement mechanisms for the actions that are recommended in the HSP. 
    • Administration sent an email on 8/26/22 to all parents stating that for this school year “We will be reverting back to a pre-pandemic response to illness and treat COVID in the same manner as we do other communicable diseases”. This indicates that the administration views the HSP as an outdated artifact rather than an active policy requiring adherence
    • In the future, if the district needs a mechanism to rapidly disseminate new requirements for future COVID variants or new infectious diseases, board policy 003 already provides that mechanism, for circumstances which would close any schools or jeopardize the safety or welfare of students or staff

Below is a summary of recent revisions to Policy 203 as well as my recommended changes:

I look forward to the discussion on Monday September 12, 2022. As always, I encourage residents to contact me with their comments.

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