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36TH LEGISLATURE OF THE VIRGIN ISLANDS COMMITTEE ON HEALTH, HOSPITALS AND HUMAN SERVICES The Honorable Senator Ray Fonseca Chair of Committee Testimony Presented By The Honorable Justa Encarnacion, RN, BSN, MBA/HCM Commissioner of Health on Bill No. 36-0278- An Act amending title 19, Virgin Islands Code, to establish immunization requirements for children and students enrolling in educational institutions in the Virgin Islands VIDOH Testimony on Bill No. 36.0278 Good day, Honorable Senator Ray Fonseca, Chairperson of the Committee on Health, Hospitals 1 and Human Services; Honorable Senator Hubert Frederick, Vice Chair; Committee members, 2 other Senators present, and members of the viewing and listening audience. 3 I am Justa Encarnacion, Commissioner of the Virgin Islands Department of Health. Joining me 4 today are Assistant Commissioner Dr. Nicole Craigwell-Syms; Assistant Commissioner Reuben 5 Molloy; Chief Legal Counsel Mackiesh Taylor-Jones; Deputy Commissioner for Human 6 Resources and Workforce Development Joan Jean-Baptiste; and Director of Immunization 7 Monife Stout. 8 Thank you for inviting us to provide testimony on Bill No. 36-0278, an Act amending Title 19 of 9 the Virgin Islands Code to establish immunization requirements for children and students 10 enrolling in educational institutions in the Virgin Islands; to provide for immunization 11 exemptions; and to require electronic reporting of immunization compliance to the Virgin Islands 12 Department of Health through the Virgin Islands Immunization Registry System (VIIRS), 13 sponsored by Senator Ray Fonseca. 14 I would also like to take this opportunity to thank Governor Albert Bryan Jr. and Lieutenant 15 Governor Tregenza A. Roach for their continued guidance and support, along with my 16 colleagues throughout the Governor's Cabinet. 17 18 Immunization Program Description 19 The Virgin Islands Immunization Program is responsible for ensuring that uninsured and 20 underinsured individuals have access to lifesaving vaccines that prevent disease, disability, and 21 death. The program is 100 percent federally funded and works closely with the Centers for 22 Disease Control and Prevention (CDC) to ensure that vaccines administered throughout the 23 Territory are current, properly administered, and readily accessible. The program also supports 24 providers in increasing vaccination rates, addresses vaccine hesitancy and exemption concerns, 25 and utilizes targeted public education campaigns to communicate the importance of 26 immunization. 27 VIDOH Testimony on Bill No. 36.0278 The Immunization Program consists of four core components: 1 Vaccines for Children (VFC) and Surveillance – Focuses on childhood and preschool 2 immunizations for eligible uninsured and underinsured children and encourages provider 3 participation in the program. 4 Hepatitis B and Epidemiology – Focuses on maternal and infant health, including the 5 prevention of perinatal Hepatitis B transmission. 6 Adolescent Vaccines – Promotes recommended vaccines for teens and young adults, including 7 HPV, Tdap, and meningococcal vaccines. 8 Adult Vaccines and Pandemic Influenza – Focuses on adults aged 19 years and older, as well 9 as emergency preparedness and response related to vaccine-preventable diseases. 10 A critical component supporting these efforts is the Virgin Islands Immunization Registry 11 System (VIIRS), a confidential, population-based electronic database that records immunizations 12 administered by participating providers throughout the Territory. 13 14 Provider Reporting and VIIRS Section 15 A major accomplishment of the Immunization Program was the restoration of the Virgin Islands 16 Immunization Registry System (VIIRS) in January 2020 after the database sustained significant 17 damage during the 2017 hurricanes. With support from the CDC's Immunization Information 18 Systems Program, VIIRS was successfully rebuilt as a cloud-based platform. 19 Over the past six years, the Department has focused heavily on improving data quality, including 20 completeness, accuracy, validity, consistency, timeliness, availability, and usefulness. High- 21 quality data are essential to monitoring immunization coverage, identifying gaps in protection, 22 responding to vaccine-preventable disease outbreaks, and supporting informed public health 23 decision-making. 24 VIIRS currently contains immunization records dating back to 2009, providing a comprehensive 25 source of vaccination information for the Territory. 26 VIDOH Testimony on Bill No. 36.0278 DOH clinical staff and vaccinating providers participating in the Vaccines for Children (VFC) 1 Program, the Section 317 Adult Vaccine Program, and independent provider practices have been 2 trained in the use of VIIRS. Despite these efforts, provider participation and reporting remain 3 below desired levels. The program's goal is to have 90 percent of vaccinating providers 4 onboarded and actively reporting to VIIRS. Currently, 77 percent of providers are enrolled, and 5 only 74 percent are consistently reporting immunization data, according to the 2024 6 Immunization Information System Annual Report. 7 To address this challenge, the Department used federal grant funding awarded in 2023 to help 8 offset the costs of establishing interoperability between provider electronic health record systems 9 and VIIRS. While several providers accepted this support, others did not. The Department is now 10 conducting provider focus groups to better understand barriers to reporting and identify 11 opportunities to improve participation and data sharing. 12 13 Data Quality Statement 14 Current data indicate that 820 children born between January 1, 2020, and December 31, 15 2025, are currently classified as unvaccinated within VIIRS because no vaccination record, 16 exemption, or documented refusal exists in the system. This creates uncertainty regarding 17 their true vaccination status and highlights the importance of complete and timely 18 immunization reporting. 19 20 Religious Exemption Recommendation 21 Recently, Immunization Program Director Monife Stout attended the National Adult 22 Immunization and Influenza Summit. During the summit, data presented by American Families 23 for Vaccines, the nation's first pro-vaccine political advocacy organization, demonstrated that 24 states which have eliminated religious exemptions have experienced significant improvements in 25 vaccination rates. These states include California, Maine, Mississippi, New York, and West 26 Virginia. 27 VIDOH Testimony on Bill No. 36.0278 Therefore, the Department recommends amending the bill to remove the religious exemption 1 contained in proposed Section 4120, Outbreaks, subsection (a)(1) and (3), as a necessary public 2 health measure to increase childhood immunization rates and reduce the risk of vaccine- 3 preventable disease outbreaks within the Territory. 4 Vaccination requirements have long been recognized by the courts as a valid exercise of 5 governmental authority to protect public health, particularly in school and childcare settings 6 where communicable diseases can spread rapidly among vulnerable populations. The proposed 7 amendment applies uniformly to all students and does not target any specific religious belief or 8 practice. 9 Given the Territory's ongoing concerns regarding childhood immunization compliance, the 10 Department believes limiting exemptions to medically necessary circumstances will better 11 protect children, families, and the public while ensuring exemptions are reserved for individuals 12 who cannot safely receive vaccinations due to documented medical conditions. 13 The Department believes this approach appropriately balances parental choice with the 14 Government's responsibility to protect public health, maintain safe educational environments, 15 and reduce the risk of preventable disease outbreaks. 16 17 National Recognition Section 18 The Immunization Program is currently in the final stages of procuring a new Immunization 19 Information System that will further expand interoperability and reporting capabilities. This year, 20 the Virgin Islands achieved national recognition as one of the first two Wisconsin Immunization 21 Registry (WIR)-based jurisdictions to successfully meet Aggregate Analysis Reporting Tool 22 validation standards across all five content areas: Transport, Submission and Acknowledgement, 23 Query and Response, Data Quality, and Clinical Decision Support for Immunization. 24 As the smallest WIR-based jurisdiction, this achievement reflects the dedication of our 25 Immunization Program staff and the Department's commitment to maintaining a high-performing 26 immunization information system. 27 VIDOH Testimony on Bill No. 36.0278 Conclusion 1 In conclusion, the Department of Health strongly supports the intent of Bill No. 36-0278. By 2 codifying electronic reporting requirements and formalizing the exemption process, this 3 legislation will strengthen our immunization infrastructure, improve the completeness and 4 reliability of vaccination data, support timely public health interventions, and better protect the 5 health of children, families, and communities throughout the Virgin Islands. 6 I would like to thank the dedicated members of the Virgin Islands Department of Health 7 Immunization Program for their unwavering commitment to protecting public health. I also 8 extend my appreciation to Senator Fonseca and the members of this Committee for your 9 leadership on this important public health initiative. We stand ready to answer any questions you 10 may have. 11