* Important Hearing Information
* Tips & Suggestions for Testifying
* Talking Points
Wyoming Health Freedom Members & Supporters,
IMPORTANT HEARING INFORMATION
Released as of 1:51pm 10/25 by the Wyoming Health Dept:
Thank you for registering to provide comment during the Public Hearing on the Wyoming Department of Health Immunization Program Proposed Administrative Rules on October 28 at 12:00 pm at the Laramie County Library, Cottonwood Room, Cheyenne, WY.
For those participating virtually or on the phone, if you do not wish to speak publicly, we are providing opportunity to submit a written comment during the hearing. To do so, please send an email with your comment to firstname.lastname@example.org. Please include your first and last name, city of residence, if applicable, affiliation, and the specific Chapter and Section your comment is concerning. The email must be sent from the same address that you used to register for this hearing.
Participants attending in person will be provided with a form for written comment if they do not wish to speak publicly.
A comment will not be considered received unless submitted during the hearing window (12:00 pm - 4:00pm) from a registered email. If you wish to change your comment to a written submission, please reply to this email to notify us so that you are not called upon during the hearing to publicly speak.
Tips & Suggestions
- Offer Facts, Counter Arguments, & Personal Stories
- Have a focus & highlight the rest, each person will be allotted a 3 minute time slot. Due to time constraints not all may have an opportunity to speak, however there is now a written option to participate as stated above.
- Consider seeking a confirmation during your testimony that the wording "genuine" has in fact actually been removed from the rule change proposals. As religious exemptions forms on the health dept website currently still contain the language "I certify that I have a genuine religious objection"
- For those testifying in person, if one person misses a point, the next person can highlight on it to make sure all points are covered
- Addition of Meningococcal (serogroups A, C, W & Y)
2016-17 there were no cases of meningococcal & the last years of record available.
Average age: 21 years
Median Age: 20 years
Age Range: 4 months to 86 years
Two cases resulted in death
According to the 2017 CDC report https://www.cdc.gov/meningococcal/downloads/NCIRD-EMS-Report-2017.pdf, Wyoming was one of five states and the District of Columbia that did not participate in the 2017 Enhanced Meningococcal Disease Surveillance. The 2017 report on that CDC web page contains a map, revealing that Wyoming is in the lowest group of states showing incidence of meningococcal disease, which is the group having 0.00 to <0.06 cases per 100,000 population. Further research into Wyoming cases of meningococcal disease shows that during the 11 years from 2005 through 2015, there were very few incidences of it. The Wyoming Department of Health web page https://health.wyo.gov/publichealth/infectious-disease-epidemiology-unit/disease/meningitis/ says: "When a case of meningitis is caused by the bacteria Neisseria meningitidis it is known as meningococcal meningitis. Between 2005 and 2015 there were 21 cases of N. meningitidis in Wyoming.
2) -If approximately 7,600 Wyoming sixth graders are given the Menactra or Menveo meningitis vaccines, Wyoming can reasonably expect 76 serious adverse events and possibly 0.228 deaths in Wyoming sixth graders per year.
-If approximately 6,400 Wyoming eleventh graders are given the Menactra or Menveo meningitis vaccines, Wyoming can reasonable expect 64 serious adverse events and possibly 0.192 deaths in Wyoming eleventh graders per year.
*Student Enrollment Source: Wyoming Department of Education statistics for numbers of students in each grade
3) 2012 a mandate was proposed in the legislature: it was deemed it wasn’t worth the economic impact to Wy citizens but education would be more beneficial. What changed?
4) Everyone would be required to resubmit exemption forms.
5) Package insert for menactra showed a 1% rate of severe adverse events in 11-55 age group. Meningococcal meningitis infections far fewer than 1% of the population, so we are creating reactions in far more people than we are helping with the immunization. Source: https://www.fda.gov/media/75619/download
-According to the CDC Pink Book
0.3 percent of those with “serious adverse events” from MenACWY-D meningitis vaccine will die. Of those receiving MenACWY-CRM vaccine, 0.4 percent of those with "serious adverse events" will die.
6) According to VAERS, as of this month, there were 10,243 serious reactions and 152 deaths implicating this vaccine. 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. Menveo, Menomune, Menactra
Multidose vials of Menomune vaccine still contain thimerosal, a mercury derivative and neurotoxin
7) Meningococcal vaccine is currently available to any family who wants it and its use should not be compelled by law
8) No randomized control that included a true inert placebo group but instead another comparator/vaccine that also did not use a placebo in it’s studies. This is the only way a product can be deemed safe. HHS calls this the “gold standard” for safety trials. Except for vaccines?
9) Price per Vaccine - (includes proposed Menactra, Trumemba & others)
- Evidence of Immunity to Chickenpox
2) Not all families work with licensed physicians, PA's or CNP's. For example a Naturopath and Chiropractor for wellness care. This requirement would force them to seek a medical practitioner that is unknown to them and does not know their family.
3) Titer testing is an invasive procedure requiring blood to be drawn and sent to a lab. If the family has no insurance the cost can be prohibitive. Cost ranges from $20 at public to $150 for private pay.
4) If a parents word is not taken as truth this could create an adversarial relationship with the school district.
- Removing Patient Consent in Order to retain individual identifiable info on the IIS
2) COUNTER ARGUMENT: Removing Patient Consent in the current section 13 from Chapter 5 of the Wyoming Immunization Information System (WY IIS) in order to retain individually identifiable information in the IIS for a patient is in violation of our right to privacy. The new proposed policy establishes the ability to opt out, however informed consent is essential and will most likely be very difficult to enforce with an opt out policy alone. OPPOSE retaining individually identifiable information, which is prohibited in current policy.
3) Once an individual’s information is in the database, it can be shared with a long list of entities without the parent or individual’s knowledge or consent because federal law referred to as HIPPA, 45 CFR §164.512(b) of the Privacy Rule, permits public health authorities to do this. This federal law allows disclosure of private, protected health information without individual authorization for the purpose of preventing or controlling disease, injury, or disability, including, but not limited to, the reporting of disease, the conduct of public health surveillance, public health investigations, and public health interventions such as home visits to increase vaccination rates.
4) It seems the goal of tracking is to identify who is and more importantly who is not getting their vaccines, how about tracking vaccine injury and death for Wyoming’s children instead? THIS IS IN THE INTEREST OF PUBLIC HEALTH ! A TRUE PUBLIC HEALTH MEASURE !
5) Registries = A form of Coercion!
Advances in data collection simply make an Orwellian slippery slope even more slippery.
6) There is no protection in using de-identified “aggregate data” as this rule change is suggesting. Legislators should not be fooled by government agency bureaucrats hiding behind the guise of security and privacy from de-identified data!
- Contraindication addition - permanent or temporary for medical waivers
1) The current form does not require explanation of the contraindication and retains the patient’s right to privacy.
2) The change to the medical exemption form sets the stage for interference from the state in the decision making of the provider.
3) This was discussed in Supreme Court case Jones V State of Wyoming DOH “Such interrogation brings up concerns regarding invasion into the right of privacy and intrusion into the physician-patient relationship. Further, the legislature has provided for any student who has not been immunized to be excluded from school in the event of an outbreak of any vaccine preventable disease, thus providing a protection for all students. See Wyo. Stat. Ann. § 21-4-309(a) (LEXIS 1999). Reading the statute in pari materia, we believe the legislature has expressed a balance between protecting individual rights and protecting the public interest and see no reason to provide further conditions to the authorization of a waiver under the guise of statutory interpretation. We will not invade the province of the legislature.”
4) Also request for removal of the link to “Conditions incorrectly perceived as contraindications,” as this is NOT in the best interest of the child. This is intended to coerce doctors into denying a medical exemption for legitimate reactions that could cause long term harm to the child. New evidence shows that children with ANY seizures have an increased risk of developing a broad range of psychiatric conditions, “most notably, schizophrenia, but also anxiety and mood disorders.”
- 30 Day Catch-Up
2) Vaccines never been tested against an inert placebo, and they have NEVER been tested in any type of combination, including the 16 vaccines and 72 doses currently give in the ACIP standard schedule.
3) Health & Human Services funded a study conducted by Harvard Medical School that showed less than <1% of vaccine injuries and deaths are reported to VAERS.