The Department of Health and Human Services has proposed a series of changes to administrative rules governing the vaccine registry. The proposal can be viewed here.
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RebuildNH objects to several of these proposed changes.
- They propose changing the word “vaccine” to “immunization”. Philosophically, we object to this change as it normalizes that the only way to be immunized is through vaccination, which is not true. This is not a registry of all immunizations, just vaccinations.
- It allows NH registry data to be shared with other states (He-P 307.06 (H)(7) and (He-P 307.11). Last year the legislature prohibited sharing NH vaccine data with the federal government. We believe this is a breach of that new law because there is no way to ensure another state wouldn’t share that data with the federal government.
- It defers to what the CDC document lists as data to be collected. (He-P 307.05 (b)) The state of NH should never arbitrarily defer to a federal government bureaucracy for anything.
- “The department or health care provider shall keep any record of the transaction, including the request itself, in a HIPAA-compliant system separate from the registry when subject to HIPAA record retention requirements.” This language would essentially create an opt-out list, which is a violation of the NH constitution, the right to privacy.
Action Item
Tuesday, October 3rd, there is a public hearing on these rule changes. We are asking you to attend this meeting to object to these rule changes.
If you cannot attend, please email your objections to Allyson Raadmae and Lori Weaver.
Towards Liberty,
