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OPPOSE Wisconsin Rule Change to Mandate Meningitis Vaccines and Require Documentation Of Chicken Pox Infection

Submit Comments before 5:00 p.m. Friday 7/26/2019

Attend or Call in to Hearing on Friday7/26 from 8:30-9:30 a.m.

Dear Wisconsin NVIC Advocacy Team Members,

This is a critical action alert for Wisconsin families who care about vaccine choice.

The Wisconsin Department of Health Services is seeking to use the rule making process to increase vaccine mandates for students. This is different from a bill that passes through the legislature, though adopted rules have the same force as law.

If these regulations pass, 7th graders will be required to get a meningitis vaccine and parents will no longer be allowed to confirm that their children had chicken pox, requiring medical personnel to verify it.  These rules are another step toward taking away parental choice in medical decisions for their family and YOUR input is necessary to stop additional government overreach.

The most important way to stop these changes is to SUBMIT PUBLIC COMMENTS OPPOSING the proposed rule change by 5:00 pm on Friday, JULY 26.  It is critical that large numbers of opposition comments are received to stop this rule from passing.

ACTION TO TAKE:

  1. Submit public comments before 5:00 p.m. on Friday 7/26! Talking points below.

Use  web-site form: Select DHS 144 from “Rulemaking Projects” box.

OR

Written comments can be mailed (postmarked by 7/26) or e-mailed by 5:00 p.m. on 7/26:

Susan Uttech

Division of Public Health

Department of Health Services

1 W. Wilson St.

Madison, WI 53703

Email: susan.Uttech@dhs.wisconsin.gov

  1. Attend the public hearing in Madison on 7/26 – testify to oppose the changes.

            Friday, July 26th at 8:30 am-9:30 am.

Conference Room 751

1 Wilson Street

Madison WI  53703 Map 

  1. Call into the hearing to give public comment. Call (608) 316-9000 and use Conference ID: 7313694
  2. Send a copy of this email to your friends and encourage or assist them in writing and submitting public comments.
  3. Please send a copy of your comments to your own state legislators in the house and senate asking them to oppose these rules if they make it to the legislature for approval.  Your legislators can be found HERE:  Enter your address in the web-form.
  4. Continue monitoring the NVIC Advocacy Portal NVICAdvocacy.org to track the status of these rules or other legislation. From here, the Rules will later go before both the House & SenateHealth and Human Services Committees for approval or rejection.  Please save copies of your comments submitted to the department so you can send a copy of your comments to these committee members, with a request that they STOP these Rules when/if they are presented if the health department does not withdraw them.  

DESCRIPTION OF PROPOSED RULES & REASONS TO OPPOSE THEM

  • Proposed changes to Immunization Requirements: HERE.
  • Analysis of the rule and the additional documents: HERE
  • The most recent version of the proposed rule text: HERE.   DHS 144
  • The fiscal estimate and economic impact analysis: HERE.
  • The public hearing notice can be found HERE.

There are several proposed rule changes.  1, 2, 4 and 5 cause the most concern, with 4 and 5 being the most concerning.

1) The Department proposes to change the “substantial outbreak” classification of chicken pox and meningitis.

2) The Department proposes to change the “substantial outbreak” classification of mumps due to mumps outbreaks in “highly-vaccinated populations.”

4) Meningitis vaccine is mandated for 7th grade students.

5) Parents are no longer able to provide confirmation of their children’s case of chicken pox/varicella, requiring a health care provider to now confirm it.

TALKING POINTS:  These are listed in order of importance.  Please use your own words to state your opposition to the proposed changes and include any personal stories that support your concerns.

OPPOSE Proposed Change 4. Meningitis vaccine requirement for 7th graders.

  • There is no urgent public health crisis to justify the expensive and potentially dangerous meningitis vaccine mandate for all Wisconsin 7th graders.
  • Meningitis is very rare in the United States, with the CDC reporting a total of only 350 cases in 2017.  The 2017 US population of approximately  325.7 million, meant that 1 in 931,000 people got meningitis and 1 in 7.2 million died.  Of the 45 deaths, ONLY 14 cases were in the age group 0-23.  These numbers do NOT indicate a public health crisis.  The mandate is unnecessary.
  • Meningococcal vaccine is currently available to any family who wants it.
  • According to the CDC, Wisconsin recorded only 6 meningococcal cases in 2016 and 4 cases in 2017. The state records are slightly different, yet, in 2015, there were only 3 cases in the 14-23 age group, with one of those being in college or technical school.
  • The vaccine only has an 80-85% efficacy rate. After two years to five years, the vaccine has been found to be, at best, only about 58 percent effective. Due to the  vaccine’s effectiveness waning, the only recommendation is that ADDITIONAL vaccines be given.
  • The package inserts for meningitis vaccines, Menactra and Menveo, indicate that   “serious adverse events” occur in 1 percent of recipients.
  • According to the CDC Pink Book, 0.3 percent of those with “serious adverse events” from meningitis vaccines will die.
  • If approximately 63,000 7th graders are given the Menactra or Menveo meningitis vaccines, Wisconsin can reasonably expect 630 serious adverse events and possibly 2 (1.89) deaths.
  • This is significant since the 2015 Wisconsin data only shows 2 cases of meningitis in high school age students with NO deaths.
  • The federal Vaccine Adverse Events Reporting System (VAERS), which includes only a small fraction of the health problems that occur after vaccination in the U.S., reports 32,453 adverse events as of July 2019.  Of these, 3,955 were considered serious and there were 186 deaths, with 90 of those being in children under 17 years of age. www.medalerts.org
  • The meningitis vaccines contain neurotoxins such as formaldehyde, aluminum hydroxide, polysorbate 80, and thimerosal, a mercury derivative.
  • Meningitis vaccines list documented side effects including death, anaphylaxis/anaphylactic reaction, difficulty breathing, upper airway swelling, Guillain-Barré syndrome, dizziness, convulsion, acute disseminated encephalomyelitis, irritability, abnormal crying, fever, drowsiness, fatigue, injection site pain and swelling, sudden loss of consciousness (syncope), diarrhea, headache, joint pain, brain inflammation, and facial palsy.   BexseroMenveo,Menomune, Menactra

OPPOSE Proposed Change 5. Parental reporting of chicken pox will no longer be acceptable.  Instead, a health care provider must confirm infection.

  • It is irresponsible of the Department to insist that a child with a highly contagious, yet often a generally mild disease, visit a medical facility where other children, including those who are medically fragile, will likely be present and thus at higher risk to contract it and become one of the rare adverse outcomes.
  • Not all families have existing relationships with the list of specified medical workers, and this provision could force a family to enter into a new unwanted contractual relationship with unknown medical staff.
  • Most families will also have the financial burden of all charges, or co-pays as well as laboratory fees.
  • This change would create an environment of distrust between the school staff and the parents as the parents’ word is questioned.
  • There is no provision for a titer test to be used as proof.

The Department’s claims of “little to no economic impact” in their justification for the rule change doesn’t reflect the strong negative economic impact on Wisconsin Families

  • Wisconsin families will be required to pay for doctor visits and vaccine costs to receive newly mandated vaccines.
  • The annual cost for approximately 63,000 Wisconsin 7th graders to receive meningitis vaccines will be over $10.7 million as the CDC vaccine price list for Bexsero shows the private sector cost at $170/dose.  Add in office visit expenses and there is little doubt why there is significant support for this vaccine by those who gain financially for its mandated use.
  • Requiring Wisconsin families to pay for doctor visit to have chicken pox verified will be expensive.  For generations, many families have treated chicken pox at home, as it is generally mild.  Arranging an office visit for a case of the chicken pox would add drastically to the economic impact on the families of a sick child.

OPPOSE Proposed Change 2. Change the “substantial outbreak” classification of mumps

  • The mumps component of the MMR used in the US has been the subject of a federal whistleblower fraud suit since 2010.  Two manufacturer (Merck) virologists claimed they were forced to create fraudulent efficacy results by adding rabbit antibodies so that the vaccine could remain on the CDC schedule and Merck could retain its monopoly.
  • The reason for this change is due to mumps outbreaks in “highly-vaccinated populations,” showing the vaccine’s ineffectiveness.  A few years, 1676 Arkansas school age children had mumps and 1536 (92%) had previously received at least two doses of a vaccine containing the mumps virus.  A recent mumps outbreak amongst  100% vaccinated Navy sailors on the USS Ft. McHenry, kept it in quarantine for over 5 months.
  • The Health Department should educate families on the risks of catching mumps and how to treat it due to an ineffective vaccine.

OPPOSE Proposed Change 1. Change the “substantial outbreak” to include meningitis and chicken pox. OPPOSE the inclusion of chicken pox in the “substantial outbreak” classification due to it generally being a mild infection that can be treated at home.

OPPOSE Department’s lack of notifying the public, the MAIN STAKEHOLDER, when publishing these proposed rules changes.

  • The Department claims they contacted all stakeholders which would be impacted by the proposed rule including, “Schools, school-aged children and parents, school boards, and public and private health care providers.”
  • Parents were not included as stakeholders, neither were they adequately informed.  The Department’s effort to inform the primary stakeholder, parents of school age children, was completely inadequate.  If not for the attention by watch dog groups, this rule would be implemented without parents knowing of their ability to participate in the process to oppose it.
  • Using the Rule process to change vaccine mandates removes the process from legislators who are accountable to their voting constituents.

Sincerely,

NVIC Advocacy Team
National Vaccine Information Center
http://NVIC.org and http://NVICAdvocacy.org
https://nvicadvocacy.org/members/Members/ContactUs.aspx

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