Tale from the Field: Immunization Records and Obtaining Missing Immunizations
As the new school year has begun, we have received many calls regarding McKinney-Vento eligible students who register in an LEA without the appropriate immunization records. McKinney-Vento liaisons wonder how to follow the appropriate public health practices, but at the same time, ensure that a new student’s McKinney-Vento enrollment rights are exercised. We hope that these actual scenarios and the responses to them will help McKinney-Vento liaisons when faced with similar situations in their districts. As always, a wealth of resources are available on our website, including many recordings and documents from our previous webinars and web series.
The Tale
A temporarily housed child came into a school district office in the Finger Lakes region to register without immunization records from the previous district. The McKinney-Vento liaison wanted to know how much time the LEA had to get these records. She also wondered how much assistance she should give to the family to enable the children to be immunized.
Questions
Should an LEA enroll a child who is eligible for McKinney-Vento designation but does not have immunization records?
How long does an LEA have to obtain a student’s immunization records from the LEA where they were previously housed?
How much assistance should the McKinney-Vento liaison offer to help the family obtain missing immunizations?
Resources
Before you attempt to answer this question, review these resources:
Immunization Section of the NYS TEACHS Resource Library : https://www.nysteachs.org/immunizations
State Public Health Law: https://www.nysteachs.org/_files/ugd/10c789_c4817764d85141a2839260fd65fc604f.pdf
Allowable and Non-Allowable use of Title I Funds: https://www.nysteachs.org/_files/ugd/10c789_087f9d44bbfc4a46a96de97ba1335af0.pdf
Referral Templates: https://www.nysteachs.org/referral-templates-for-liaisons
State Public Health Law: https://www.nysteachs.org/_files/ugd/10c789_c4817764d85141a2839260fd65fc604f.pdf
The New York State Immunization Information System (NYSIIS): https://www.health.ny.gov/prevention/immunization/information_system/
Answers
Question 1: Should an LEA enroll a child who is eligible for McKinney-Vento designation but doesn’t have immunization records?
Students are entitled to immediate enrollment in school, even if they don't have their immunization records or any other documentation needed for enrollment. It is the responsibility of the enrolling district to get the records, including immunization records, from the district where the student was last enrolled.
NY State Public Health Law explains that students have 14 days (which may be extended to 30 days if need be) during which they may attend school while the school is waiting for proof of immunization. Students in temporary housing have additional protections with regard to submitting proof of immunization.
If the liaison or school nurse or is working with a family to get the immunizations (including setting up appointments, arranging transportation, and/or paying any fees), this period may be extended beyond 14 days, up to 30 days.
Question 2: How long does an LEA have to obtain a student’s immunization records from the LEA where they were previously housed?
The district where the student was last enrolled has five days to forward the records.
While liaisons should work directly with the staff of the previous district to obtain these records, there is a secondary source of immunization information as well. If the child came from another LEA in NY, you may be able to access the immunization information system for verifying eligibility for admission in the New York State Immunization Information System (NYSIIS), which is a registry of immunization information for children and youth 19 years old and younger. The system aims to establish a complete, accurate, secure, real-time immunization medical record that is easily accessible and promotes public health by fully immunizing all individuals appropriate to age and risk.
Question 3: How much assistance should the McKinney-Vento liaison offer to help the family obtain missing immunizations?
If a student in temporary housing is missing any immunizations, the parent/student should be referred to the LEA's McKinney-Vento liaison who must help the student obtain the necessary immunizations. The liaison should help the student and family find free or low-cost health clinics where they can receive all necessary immunizations. 42 U.S.C. § 11432(g)(3)(C)(iii).
Using the health referral template, the McKinney-Vento liaison can let the family know where to get the immunization(s), how to schedule them, and how to get there.
If other resources to pay for the immunizations aren’t available, Title I funds may be used to offset the cost of immunizations.
Two principles govern the use of Title I, Part A funds to provide services to homeless students.
First, the services must be reasonable and necessary to assist homeless students to take advantage of educational opportunities.
Second, Title I, Part A funds must be used only as a last resort when funds or services are not available from other public or private sources, such as public health clinics, or local discretionary funds (sometimes provided by the PTA) used to provide similar services for economically disadvantaged students.