When conducting a renewal inspection, OCDEL’s Bureau of Certification Services (BCS) is responsible for reviewing a random sample of the children’s files which include the health records. The certification representative will review the immunization documents and compare against the schedule recommended by the ACIP to determine if the health record is up to date or on a makeup schedule. If a child is missing an immunization(s), the certification representative will discuss this with the provider, issue a citation, and request a plan of correction.
There are exemptions that could affect administering immunizations for children in a child care setting. 55 Pa. Code Chapters §3270.131(e)(2)(i)(ii), §3280.131(e)(2)(i)(ii), and §3290.131(e)(2)(i)(ii) state, “That exemption from immunization must be documented as follows:
(i) Exemption from immunization for religious belief or strong personal objection equated to a religious belief must be documented by a written, signed and dated statement from the child’s parent or guardian. The statement shall be kept in the child’s record.
(ii) Exemption from immunization for reasons of medical need shall be documented by a written, signed and dated statement from the child’s physician, physician’s assistant or CRNP. The statement shall be kept in the child’s record.”
If a child’s record is not up to date due to one of the exemptions listed in 55 Pa. Code Chapters §3270.131(e)(2)(i)(ii), §3280.131(e)(2)(i)(ii), and §3290.131(e)(i)(ii) the facility will not be cited for non-compliance of the regulation for that specific child. The child’s record must be documented as stated in 55 Pa. Code Chapters §3270.131(e)(2)(i)(ii), §3280.131(e)(2)(i)(ii), and §3290.131(e)(i)(ii).
Access the printable ACIP Immunization Schedule for children and adolescents on the CDC’s website.
Department of Health (DOH) is also responsible for ensuring that children in child care group settings have the recommended immunizations as per ACIP. Current DOH procedure is to have representatives of DOH contact a random selection of Department of Human Services (DHS) certified child care providers to conduct an annual review of immunization records. Due to confusion in completing and submitting the documents in the past and specifically during COVID by DHS certified child care providers, the on-site visit from DOH will support providers in meeting the requirements outlined in 28 Pa. Code Chapter §27.77(a)(4).
Effective fiscal year (FY) 2022-2023, DOH will not audit a DHS certified child care provider in two consecutive years. The DOH annual review process is subject to change. DHS certified child care providers will be notified through a policy announcement of any updates and changes in the DOH annual review process.
To ensure compliance with DOH immunizations regulation pertaining to children in child care group settings as stated in 28 Pa. Code Chapter §27.77, tentatively between August 2022 and December 2022, a representative from either state, county, or city[1] will contact a random selection of DHS certified child care providers via telephone to set up an appointment to visit the DHS certified child care facility. The visits will be in person due to DOH following Federal guidance that in person activities are to resume whenever possible. DOH will review the immunization records for all children between the ages of 2 to 59 months who are enrolled at the facility. At the time of the initial contact, the DOH representative will ask how many children between the ages of 2 to 59 months are enrolled at the facility, as the length of the visit is contingent on the number of children in this age range enrolled at the facility. During the visit, the immunization information will be entered into the CoCasa program (Comprehensive Clinical Assessment Software Application). A report will be generated from CoCasa supplying information on the status of each child enrolled at the facility who is not up to date on their immunizations.
The DOH representative will review the results with the DHS certified child care provider and will discuss what course of action is needed to bring the child(ren) up to date with their immunizations. At the conclusion of the visit, the DOH representative will provide a copy of the CoCasa report to the DHS certified child care facility. The DHS certified child care provider should use this report to take the necessary steps to bring the immunization records up to date.
The DOH representative will also discuss and review exemptions that affect a child’s ability to follow ACIP recommendations. The CoCasa report will not include a child(ren) who meets the exemptions state in 55 Pa. Code Chapters §3270.131(e)(2)(i)(ii), §3280.131(e)(2)(i)(ii), and §3290.131(e)(i)(ii). During the visit, the DOH representative will provide information and share resources that are available to the DHS certified child care provider to assist in ensuring that children’s records are up to date.
The DOH representative will send a copy of the report generated by CoCasa for each facility that has a child(ren) with immunization records that are not up to date to DHS OCDEL. The report will include the name, date of birth, and a list of the vaccinations that are needed for each child who is out of compliance at the facility. The certification representative assigned to the DHS certified child care facility will conduct a review of the immunization record(s) for the child(ren) in question. The certification representative will discuss the record(s) with the DHS certified child care provider and, if at the time of the review, there are still noncompliance a citation will be issued and a request for a plan of correction to bring the child(ren)’s record into compliance will be made.