AZ Vaccination Exemptions Continue to Increase

Despite numerous interventions in the last year designed to improve immunization rates among AZ school children- we continue to lose ground.  Last week the ADHS released their latest school reporting data on vaccine exemption rates (medical, personal and religious).  Here’s a 2 page summary of some of the results.  This year’s report covers the 2017-2018 school year (the data was submitted by the schools to the Department in the Fall of ’17). The data show that:

  • Immunization rates have decreased across age groups from 2012 to 2017;

  • Non-medical exemption rates continue to be highest in public charter schools, followed by private and public schools in 2017; and 

  • Non-medical (e.g. personal and religious) exemption rates have increased from 2016: going from 3.9% to 4.3% for pre-school; 4.9% to 5.4% for Kindergarten and 5.1% to 5.4% among 6th graders.

The Arizona Public Health System has done a remarkable job turning the data reported by schools into actionable information.  My favorite is the Personal Belief Exemptions Map.  Parents can also look up the exemption rates in individual schools.  But there are also data for: Arizona Reporting Schools Coverage; County Kindergarten Coverage; County 6th Grade Coverage; County Child Care Coverage; Whooping Cough Immunization Coverage Map; and a Measles Immunization Coverage Map.


Interventions to Reduce Vaccine Exemptions

The ADHS has significantly overhauled their vaccine exemption form to better inform parents about the risks that they are taking for their child and for their child’s classmates and the community by choosing not to vaccinate their kid. Other interventions (by the Arizona Partnership for Immunizations) have included working with school administrators to help parents overcome any barriers that might be preventing them from getting their children vaccinated and by reducing “convenience exemptions,” in which parents sign a waiver because they can’t get their children immunized in time to meet school requirements.

I’ve also heard that there is an Immunization Education Course under development by the ADHS that’s designed to serve in lieu of a new exemptions form has been built and piloted at some schools in Maricopa County.

During the 2015 legislative session, Representative Mendez sponsored HB 2466 which would have required all public schools (including charter schools) to maintain a website to post the rates of their pupils’ immunizations against vaccine preventable diseases.  It never even received a committee hearing.  Back in 2012 a Bill that would have required a doctor’s signature to get a personal exemption failed. 

A couple of years ago California eliminated personal exemptions entirely.  While the rate for personal exemptions rose after the personal exemption was eliminated, a study In study in JAMA back in 2017 found that the rate of medical exemptions for immunizations for incoming kindergartners rose the year after California eliminated the personal-belief exemption, but vaccination rates did improve substantially - especially in high income enclaves that had the highest personal exemption rates. 

By the way- last week the Second District Court of Appeal in Los Angeles found that California didn’t violate freedom of religion or the right to an education when it eliminated most exemptions.  The court said that… “Compulsory immunization has long been recognized as the gold standard for preventing the spread of contagious diseases”.  The court said the new law was not discriminatory and was a valid measure to protect public health.

AzPHA Letter to ADHS on Proposed Immunization Rulemaking for School Vaccination Requirements

March 15, 2018


Cara M. Christ MD


Arizona Department of Health Services

150 N 18th Avenue

Phoenix, AZ  85007


RE: Vaccination Rulemaking

Dear Director Christ:

I write on behalf of the Arizona Public Health Association (AzPHA) – one of Arizona’s oldest and largest membership organizations dedicated to improving the health of Arizona citizens and communities.  An affiliate of the American Public Health Association, our members include health care professionals, state and county health employees, health educators, community advocates, doctors, nurses and students.

The AzPHA has examined the Arizona Department of Health Services (ADHS) proposed Rulemaking to revise the rules in 9 A.A.C. 6, Article 7, Required Immunizations for Child Care or School Entry.  We are generally supportive of the rule package as it appears to clarify and improve the requirements for personal, medical and religious exemptions, makes the rules more consistent with standard medical practices, and better allows for electronic records and record-keeping.

However, we believe that the Department is missing an opportunity to update the child care and school vaccine requirements so that they are consistent with the CDC’s Advisory Committee for Immunization Practices (ACIP) recommendations.  As you know, rulemaking packages are resource intensive and time consuming, and this may be the only opportunity for many years to update the Department’s vaccine requirements.

We urge the ADHS to update the requirements so that they (over time) are consistent with ACIP recommendations by adding a 2nd Varicella vaccine, the PCV 13 series, Rotavirus, and 2 Hepatitis A doses to the child care requirements.  We also urge you to add a 2nd Meningococcal vaccine, and the Meningococcal B at 16 years old to the school requirements.  We recognize that ARS 36-672 (C) prevents you from being able to add the Human Papilloma Virus Vaccine to the vaccine requirements.

We understand that the requirements may need to be phased in so that pediatricians and families have the time needed to become compliant with the new requirements. 

For example, the ADHS could write the final Rule such that the vaccines with the highest current coverage levels (as reported in ASIIS) are phased in over the next 18 months.  Vaccines with lower current coverage levels could be phased in at later dates. 

This approach would allow the Department to responsibly phase the vaccine requirements using coverage projections while being a good steward of future Department Rulemaking resources and at the same time secure a healthier future for Arizona children and families.


Will Humble, MPH

Executive Director,

Arizona Public Health Association