Is the NJDOH Trying to Sneak Mandates Through a Back Door?

By Ann Tomoko Rosen

On the heels of Chelsea Clinton’s announcement of “The Big Catch-up” initiative, a global effort to boost vaccination rates among children following the COVID-19 pandemic, the New Jersey Department of Health (NJDOH) is reviewing troubling revisions to New Jersey’s current vaccine requirements.

On May 8, the NJDOH sent out a message requesting “stakeholder feedback” for proposed rule revisions of New Jersey Administrative Code Title 8 Chapter 57, which covers School Immunization Requirements, Communicable Diseases and related topics. This is an opportunity we should not miss.

The current rule is set to expire on February 8, 2024.

The agency is considering policy changes that would align school immunization requirements with current ACIP (Advisory Committee on Vaccine Practices) requirements. This could pave the way for bypassing the legislative process typically employed to determine vaccines mandates in New Jersey would result in the immediate addition of COVID, flu and HPV shots to attend school if adopted. All interested “stakeholders” are invited to provide comments until May 31, 2023.

The New Jersey Coalition for Vaccination Choice (NJCVC) received proposed changes and is asking parents to consider submitting comments and sharing their concerns with local legislators. Included in the proposed revisions to the Immunization of Pupils in School (N.J.A.C. 8:57-4) are the following:

For Immunization of Pupils in Schools (N.J.A.C.8:57-4)

• Align immunization requirements specified in this subchapter with the current ACIP recommendations.
• Not limit a private entity’s ability to add additional vaccination requirements that are recommended by the ACIP but not required by NJDOH.
• Utilize NJDOH’s request for Medical Exemption from Mandatory Immunization (IMM-53) form to file all medical exemptions.

For Higher Education Immunization (N.J.A.C.8:57-6)

• Add the new meningococcal vaccine requirement in accordance with the ACIP recommendations as a condition of attendance to comply with (C.18A:62-15.1).
• Not limit a private entity’s ability add additional vaccination requirements that are recommended by the ACIP but are not required by the NJDOH.

NJPHIPAC (New Jersey Public Health Innovation Political Action Committee) has created a video summarizing the changes under review here:

If accepted, these changes could place future decision-making around New Jersey’s school vaccination requirements in the hands of the CDC’s ACIP committee and remove the role of legislative process. Based on the current ACIP schedule, this revision would immediately add COVID, Influenza, and HPV (Human Papilloma Virus) vaccines as requirements for school attendance. Given the vast number of new vaccines in development, our school children could potentially be subject to an ever-growing vaccination schedule. Changes could also broaden access to private health information.

Comments can be submitted here.

Setting Up A Disclaimer?

Unfortunately, we are seeing that regulatory authorities are unwilling to take responsibility for the unintended consequences of their recommendations when things go wrong. The NJDOH is already distancing itself from the potential impacts of proposed changes. From an article in NJ Spotlight News:

According to briefing materials provided to some stakeholders, the proposal also calls for further aligning the state’s immunization requirements with federal guidelines. Those federal recommendations now urge children to receive vaccines for COVID-19, influenza and human papillomavirus, or HPV, among other shots not currently on the state’s list.

But state officials insist they are not seeking to expand the list of required childhood vaccines, just incorporating updated federal guidance for shots already mandated for school attendance.

Is the Department of Health setting itself up for a “just following orders” scenario? This is particularly troubling when dealing with liability-free medical interventions given to children.

At least one NJ legislator is calling them out. In a May 10 press release, Senator Holly Schepisi had this to say:

“Getting any of these shots should be a choice that parents make for their children after considering the recommendation of their doctors…

Using the blunt force of government to compel parents to make a choice between getting these particular vaccines for their children that they don’t want or taking them out of public school is just wrong. The Murphy administration knows parents will be outraged and that vulnerable Democratic members of the Legislature who are up for election in November won’t pass the controversial legislation mandating these vaccines, which is why they won’t even admit this is happening. If they say they’re not ‘considering it at this time,” that’s just code for ‘until after Election Day.’ If there truly is no intent to mandate these vaccines in order for children to attend school, I call upon the DOH to directly address their intentions to the parents of New Jersey.”

This is NOT About Health

All vaccine mandates are an affront to informed consent and the doctor-patient relationship, as the one-size-fits-all medical interventions inevitably cause harm to some children. Much of the population is now learning of the poor study designs and serious adverse events linked to many vaccines as well as the conflicts of interests among the organizations tasked with determining the safety and efficacy of vaccines. Furthermore, medical exemptions are virtually impossible to acquire in New Jersey, as doctors now face intense scrutiny for writing them and children must demonstrate significant prior harm attributed to specific vaccines to be medically exempt from receiving future doses.

Additionally, some ACIP-recommended shots serve no purpose in protecting public settings as they either fail to stop infection and/or transmission (ie. COVID, pertussis) or they are for infections that cannot be transmitted in school settings (HPV).

A Bigger Picture

Proposals to bypass the legislative process that currently determines vaccine mandates are likely part of a global campaign to address vaccine hesitancy.

Last month, the WHO, the Bill & Melinda Gates Foundation, UNICEF, Gavi, the Vaccine Alliance and Immunization Agenda 2030 announced the launch of their latest global initiative “The Big Catch-up”, described as a “targeted global effort to boost vaccination among children following declines driven by the COVID-19 pandemic.”

Once again, their approach mirrors a key failure of the current healthcare system as they join forces to tackle symptoms rather than stopping to examine the roots of what they perceive to be a problem. Instead of examining the legitimate concerns of parents who are reluctant to subject their children to a growing list of vaccines, public health organizations have joined forces to find loopholes around due process, informed consent and parental rights.

At Fortune’s Brainstorm Health Conference in Marina del Rey, California, Chelsea Clinton lamented:

“I spend a lot of time thinking about the really unfortunate, to try to use a not too judgmental word, rise in not only vaccine hesitancy and questioning, but outright rejection of vaccines and of kind of science and the scientific process and also too often on our scientists, our epidemiologists, our front line health care workers.”

The staunch vaccine proponent also addressed her concerns about “stripping away of public health emergency powers from state public health agencies,” despite the fact that those powers are used to strip away the rights of U.S. citizens.

These groups aren’t interested in understanding our concerns. They are looking to bulldoze over them. We can’t let that happen. We need to reclaim the conversation around children’s health and informed choice. When it comes to the health of our children, parents ARE stakeholders.

If you have concerns about these and other measures that are being proposed, please take this opportunity to let the NJDOH know. You can submit your comments here.

Additionally, please address your concerns with your state legislators. You can find your representatives here.