A Voice for Choice Advocacy wrote a detailed letter (Click here to view the letter) in response to these regulation changes. Most were small, requested changes, but there were 5 significant requests we made:
– Add that homeschoolers are exempt from vaccination. – Add that pupils with an IEP are exempt vaccination – Remove requirement of the varicella vaccine for 7th grade entry
– Remove requirement that temporary medical exemption can only be valid for 12 months
– Change definition of Licensed physician to include out of state physicians with an equivalent license
Now that the California Department of Public Health has our, and others’, comments, they will update the proposed regulations draft with some or all of these suggestions. Once updated, CDPH has to decide if the changes are nonsubstantial or substantial. Nonsubstantial changes do not alter the regulatory effect of the proposed provisions; therefore, no further notice is required. Substantial changes alter the meaning of the regulatory provisions and require further notice to the public and must be made available for public comment for at least 15 days. (Details of the Rules and Regulation process can be found here: http://www.oal.ca.gov/rulemaking_participation/)
A Voice for Choice Advocacy is pretty sure that the changes CDPH adopts will be considered substantial and we will therefore have another opportunity to give comment on these changes.