Oversight of Student Immunization in Schools

Issued Date
August 16, 2016
Health, Department of
State Education Department


To determine if the Department of Health (DOH) and State Education Department (SED) are following the State’s public health procedures to ensure New York’s schools are adequately preventing, and are prepared to respond to, outbreaks of vaccine-preventable disease. Our audit focuses on schools outside New York City and covers the period September 1, 2013 to March 31, 2016.


SED provides guidelines to assist schools in developing policies to prevent and prepare for outbreaks of serious communicable diseases. The guidelines are available on SED’s website and include updated immunization requirements, customizable sample health forms, and guidance on granting religious and medical immunization exemptions, with links to the applicable laws and regulations. Additional resources can be located online at SED’s technical assistance center. Schools are authorized to grant or deny individual immunization waivers requested by parents or guardians for religious or medical reasons. Pursuant to the State Education Law, SED is responsible for hearing appeals related to exemptions that are denied at the local level. DOH’s mission is to protect, improve, and promote the health, productivity, and well-being of all New Yorkers. Its Bureau of Immunization collects vaccination information for schoolchildren via an online survey (Survey), which all schools complete annually. Survey data is reported by school year, covering September through June.

Healthy People 2020 is an initiative led by a group of federal agencies that provides sciencebased, 10-year objectives for improving the health of all Americans. New York State has adopted its recommended 95 percent target rate of childhood immunization to achieve what the initiative terms “herd immunity.” For the 2014-15 school year, 4,041 schools outside New York City completed the Survey, accounting for more than 1.8 million students. Their overall reported rate of complete immunization (CI) was 97 percent.

DOH carries out the enforcement and monitoring of immunizations in schools across the State and performs between 100 and 150 audits per year to validate Survey data reported by schools. These audits generally include those schools with CI rates below 90 percent, along with other locations selected at random. For 2014-15, data showed 456 schools outside New York City had CI rates below 90 percent.

Key Findings

  • DOH and SED have both provided appropriate assistance to schools to guide their immunization programs. Overall, these agencies also have appropriate controls in place to ensure schools are adequately preventing, and are prepared to respond to, outbreaks of vaccine-preventable diseases.
  • Immunization rates across the State are generally above standards established to limit the risk of a serious outbreak. However, our analysis of the Survey data found schools in some counties have high exemption rates, most notably Yates and Montgomery counties, where 5 to 10 percent of the students were granted exemptions by the schools. The higher exemption rates put schools in Montgomery County (at 89 percent) and Yates County (at 86 percent) well below the 95 percent target rate for childhood immunization coverage. Also, schools in four other counties (Allegany, Columbia, Rockland, and Ulster) had immunization rates of 94 percent, just short of the 95 percent target.
  • Our analysis of Survey data shows there are pockets of at-risk populations that are more likely to have low immunization rates. This is particularly evident at private schools and schools with proportionally larger international and migrant student populations. Through better use of data, the agencies may be able to better target their on-site efforts to further improve immunization rates and reduce overall risk to students.

Key Recommendation to DOH

Use additional risk factors, such as those detailed in this report, to identify higher-risk schools and better target audit and technical assistance efforts.

Other Related Audit/Report of Interest

Department of Health: Nursing Home Surveillance (2015-S-26)

John Buyce

State Government Accountability Contact Information:
Audit Director: John Buyce
Phone: (518) 474-3271; Email: [email protected]
Address: Office of the State Comptroller; Division of State Government Accountability; 110 State Street, 11th Floor; Albany, NY 12236