Testimony Before the Council of the District of Columbia Committee of the Whole at the Public Roundtable on: “No Shots, No School” for School Year 2022-2023

Jun 29, 2022

Good afternoon, Chairman Mendelson and members of the Committee. My name is Rachel Johnston and I am the Director of Special Projects at the DC Charter School Alliance, the local non-profit that advocates on behalf of public charter schools to ensure that every student can choose high-quality public schools that prepare them for lifelong success.

As always, charter schools are committed to providing safe and nurturing learning environments for the nearly half of DC public school students they serve and the approximately 10,000 teachers, staff, and leaders who support them. But unless the city improves cross-sector coordination efforts, updates messaging, and fixes unreliable data systems, the current ‘No Shots No School’ policy will exclude a staggering number of students from attending school this fall – creating a huge educational equity issue for schools and families to navigate.

Enforcing ‘No Shots, No School’ an Education Equity Issue

Based on estimates from various city agencies, we believe the current number of public school students not compliant with ‘No Shots, No School’ (which includes both routine vaccinations and COVID-19 vaccines) is somewhere between 20,000 and 40,000 students. That means, at a minimum, approximately one in every five students – and as many as four in 10 students – could be excluded from valuable instruction time after the first 20 days of school.

To be clear, charter school leaders want their students to be vaccinated. But we cannot do so by disregarding the city’s most under-resourced communities, who would be disproportionately affected by enforcing ‘No Shots, No School’ as it currently stands.

Too Large a Burden Placed on Schools

We heard helping students get into compliance with ‘No Shots, No School’ would be a citywide effort. But in reality, too much of this burden is placed on schools – and they are doing everything they can to help students get vaccinated. Schools are well underway with collecting the necessary paperwork and many are hosting vaccination clinics, thanks to Children’s National Hospital, whose partnership has been invaluable in equitably sharing limited vaccination resources with our schools.

But these efforts ultimately will be inadequate to get enough students vaccinated in time. To substantially increase vaccination rates, our schools need deeply integrated cross-sector supports and accountability across the city. We still are not seeing that in the city’s approach.

For example, right now, 29 local education agencies do not have nursing support from DC Health’s School Health Suite program, which supports vaccination paperwork collection. We are grateful to Superintendent Grant for responding to our request and offering access to patient care technicians (PCT), who will be helpful in supporting ‘No Shots, No School’ compliance. But, there are limitations to what PCTs can do for students. While they can help with ‘No Shots, No School’ compliance and COVID-19 care, they do not provide full nursing services for students.

Additionally, even when a school does have a nurse and a PCT, we need the city to provide greater clarity on each of their roles across LEAs. Who should a student see if they show a symptom consistent with both COVID-19 and another illness during summer school and throughout next school year?

The point is this: throughout the pandemic, the burden for implementing policies the city enacts has fallen again and again to LEAs – adding to a long list of responsibilities school leaders already must manage. And while our schools are nimble, responsive, and innovative, they are not healthcare specialists, or policy implementation experts – nor should they be expected to be.

We understand OSSE is providing immunization compliance materials to other DC government agencies like the Department of Parks and Recreation and the Department of Housing and Community Development. But we need the city to expand the agencies assisting with coordinated and clear messaging, scheduling well visits for families, and providing vaccination opportunities to include the Child and Family Services Agency, the Department of Employment Services, and other social service agencies and organizations that interact with families.

Lack of Clear, Transparent Messaging

Schools also need the city’s messaging about vaccination requirements to be more clear and transparent. For example, a new version of the Universal Health Certificate families are asked to submit that reflects the COVID-19 vaccine requirement for eligible students is not publicly available. Additionally, DC Health’s ‘No Shots, No School’ advertisements on bus stops say the COVID-19 vaccine is recommended for eligible age groups (see the photo from a Mt. Pleasant bus stop). This presents a problem. If families are receiving competing messages from their schools, public advertisements, and official government forms, how can we expect them to fully comply with ‘No Shots, No School’ requirements?

Unreliable Data and Systems Make Operationalizing ‘No Shots, No School’ Challenging

Third, if our schools are going to properly operationalize ‘No Shots, No School’ they need user-friendly data from DC on immunization compliance. We understand DC Health has rolled out The District of Columbia Immunization Information System (DOCIIS) 2.0 and that Children’s nurses have access, but many school administrators still do not. We testified in February about the urgency of rolling out this important data system in sufficient time to fully operationalize ‘No Shots, No School.’ Additionally, we have heard about accuracy issues with data in the system’s reports, making it challenging to trust its validity. When schools don’t have accurate data to understand their compliance rates, family engagement efforts can be severely damaged. Schools rely on this data to strategically target their communications. If the DOCIIS 2.0 system isn’t accurately reflecting that a student has met vaccination requirements, and then schools reach out to that family asking them to get in compliance, it causes frustration and can damage trust between the family and school.

The key to recovery is deep family engagement. We cannot hamper those efforts because of bad data.

Moving Forward

The health and safety of charter school students is a top priority. But the city cannot place the burden on schools of both ensuring that students’ health needs are met and that their academic needs are met. We need the city to be true partners in the effort to increase vaccination rates and provide safe learning environments so that schools can accelerate students’ learning and continue down the road to recovery. Greater cross-sector supports, clearer, transparent messaging, and reliable data systems are three important ways we can collaborate to help accomplish these goals. However, we need to be realistic about what is possible with limited time. Many schools will be starting again in early or mid-August. Without these changes, schools should not be expected to exclude students.

Thank you for your time and attention to this matter, and I welcome your questions.