Make ImmTrac an Opt-Out System

Testimony by Ari Brown, MD

House Public Health Committee
House Bill 772 by Rep. Donna Howard
March 13, 2013

Good afternoon Madame Chair and distinguished members. My name is Dr. Ari Brown. I have been a practicing pediatrician for 17 years and am a member of the Texas Pediatric Society Committee on Infectious Diseases and Immunizations. I am here today on behalf of the 47,000 physician members of the Texas Medical Association and Texas Pediatric Society to speak in support of the committee substitute of House Bill 772 by Representative Howard.
As a pediatrician, providing vaccines is one of the most important services I provide my patients. Ensuring that children are immunized at the appropriate times to adequately protect them from vaccine preventable disease is imperative, and keeping a record of those vaccinations for school entry, public health emergencies, and to avoid duplicating immunizations is a crucial part of that process. Our immunization registry, ImmTrac, is a critical component of our public health system and necessary for keeping kids healthy. The vast majority of my patients recognize the benefits of the registry. Over 90 - 95% of Texans choose to include their records in ImmTrac, though because Texas currently operates what is referred to as an “opt-in” consent process, each of these patients must complete a form that is submitted to the Department of State Health Services - and consent must be entered into the system before vaccination records can be added to the registry.

In my experience, the current process of consent for inclusion in ImmTrac is burdensome and ultimately can inhibit a provider’s ability to access complete immunization histories for the children we serve. At the point of care, physicians must gather and document consent for those who want to be included in the registry. Most medical offices are operating at maximum capacity, and the time-consuming consent process occupies valuable staff resources that are needed for patient-care. Moving to an “opt-out” system of consent will mean that providers can advise families that their information will be entered into ImmTrac unless they specifically “opt-out” of the system.  This means that we would only be required to process forms and provide documentation for the small subset of the population which declines to consent—between 5 and 10% of our patients, as opposed to the current “opt-in” system which requires documentation of consent for 90 – 95% of those we immunize. Alleviating administrative burdens under an “opt-out” system would free up staff time for more appropriate patient-care activities and would ensure that we more efficiently document immunizations to support the public health infrastructure in Texas.  

In order to promote system efficiencies, moving to an “opt-out” consent process makes sense. We absolutely respect the right of Texans to keep their records out of the registry, and will gladly continue to offer that as an option. The only difference we will see by moving to an “opt-out” system is that we will be completing the paper work for a much smaller segment of the population, which will save time and money for patients, physicians, and our Department of State Health Services. It is time we move to a system that suits the needs of the vast majority of our population and adopt an administrative process that allows us to more effectively and efficiently direct our limited resources to patient care. We urge you to support the committee substitute for House Bill 772. Thank you for your time today. 

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