The immunization registry is a tested and standard tool which provides critical information on vaccinations for use in monitoring immunization programs, guiding public health action, and keeping accurate records. Used by 49 other states and DC, as a Public Health Strategist at the City of Nashua’s Division of Public Health and Community Services, I know how registries help increase vaccination records and reduce vaccine-preventable disease and suffering. The more information in the registry, the more useful the database is to public health, which is why I urge lawmakers to oppose HB 1606. This bill would change the immunization registry from opt-out to opt-in, creating new barriers to participation, limiting the data available, and leaving the state without a critical tool to inform its public health response.

The New Hampshire registry, the Immunization Information System (NHIIS) was adopted in 2021 and was a huge step forward for NH data collection around immunization and communicable disease. It was created with the intent to consolidate a citizen’s immunization information from multiple NH health care providers who participate in NHIIS into a single reliable record. Keeping immunization information in one location helps providers know what immunizations you and your family have had and which immunizations you will need in the future. In the event someone relocates or moves, changes health care provider(s), during natural disasters, such as flood or hurricane, or a disease outbreak, all of participating health care providers will have access to immunization information. Or in the event of a disease outbreak, NHIIS will assist in identifying when a patient requires immediate vaccination.

Overarching, the intent of the NHIIS is the goals of capturing 100% of the vaccinations provided to patient within the state and to maintain the confidentiality and security of all patient information received in the NHIIS. As a public health department, and a public health professional, I am most concerned about the benefits of the NHIIS that can help us better reach the most vulnerable populations. The system is not a tool to spy on citizens and target them because of their vaccination status – an unfortunate assumption made during this tenuous pandemic political climate.

The current law allows for individuals and families to “opt-out” of the system, while the proposed HB 1606 would make it so that patients have to explicitly “opt-in” to NHIIS. Changing the system to opt-in will erect barriers for patients and providers alike and will minimize the impact this public health tool can potentially have on the health of NH.

Opt-out is the preferable policy as there are fewer barriers to participation. When a patient/family has to “opt-in” we are creating more administrative barriers for an already overburdened health care system. In addition, if providers are not able to have enough of their patients opt-in, they potentially lose the benefit that the system is meant to provide. The usefulness and success of NHIIS is contingent on the enrollment of as much of the population as possible. Public Health Departments such as my own, can run reports and see if there are certain zip codes/neighborhoods that require more outreach to improve immunization among school-aged children for example.

But let’s put something that gets people’s attention: Money. Obtaining affirmative consent imposes significant costs. “Bloom et al. (2010) (https://pubmed.ncbi.nlm.nih.gov/20431419) attempted to calculate the cost for hospitals if the Texas government adopted opt-in policies for tracking immunization health records for children in the state. The study found that obtaining consent for each child born in the state would cost roughly $1.4 million or roughly $2 per child per year. Conversely, switching to an opt-out system would reduce this annual cost to $110,000 or $0.29 per child, which could redirect limited healthcare funding to critical areas, such as vaccine purchasing.” (ITIF, October 2017 – https://itif.org/publications/2017/10/06/economics-opt-out-versus-opt-in-privacy-rules) And that was 2010, costs have increased since.

Jane Goodman is a public health network strategist for the city of Nashua’s Division of Public Health & Community Services.