Early childhood services and immunisation requirements
What are the immunisation requirements for a child to enrol and attend an early childhood service?
Following changes to the South Australian Public Health Act 2011 (the Act), from 7 August 2020, children will not be able to enrol in or attend early childhood services unless all immunisation requirements are met.
The Act states:
an early childhood service must not enrol a child if all immunisation requirements are not met
a child cannot attend, or continue to attend, an early childhood service if all immunisation requirements are not met
early childhood services must keep a current copy of an approved immunisation record for each child enrolled in, or attending that service, and
approved immunisation records must be supplied by parents/guardians to the early childhood service at specified times.
What does ‘all immunisation requirements’ refer to?
The National Immunisation Program (NIP) provides funded vaccines at specific ages to babies, toddlers, adolescents and adults eligible for a Medicare card.
Vaccines must be administered on, or close to, the specific schedule points for children to be considered up to date with their immunisations; usually a few days before or a few weeks after is acceptable.
Vaccines that are administered under the NIP are recorded on the Australian Immunisation Register (AIR).
Unless the child has an approved exemption, if a child has not received all of their scheduled vaccines at the specific schedule points or as per a recognised catch-up service, then the AIR records the child as being ‘not up to date’.
What are ‘approved immunisation records’?
For most children, an approved immunisation record will be an 'immunisation history statement', which is downloaded from the Australian Immunisation Register (AIR).
The immunisation history statement is an official record of immunisations given to a child, and it will also indicate if a child has any approved exemption.
In very rare circumstances, a certificate from the Chief Public Health Officer or a document approved by the Chief Public Health Officer may be accepted.
A letter from a GP, an overseas immunisation record or the South Australian Child Health and Development Record (the “Blue Book”) are not considered approved immunisation records.
What is a catch-up schedule?
A child is registered for a catch-up schedule on the Australian Immunisation Register (AIR) when they have missed some vaccines as per the National Immunisation Program (NIP) schedule.
If the child’s immunisation history statement indicates the child is on a catch-up schedule the child is eligible to attend the service.
A child can only be registered as being on an approved catch-up once.
What are the approved exemptions from meeting all immunisation requirements?
There are two processes that enable exemption from meeting all immunisation requirements. They are:
the Commonwealth Governments legislation, A New Tax System (Family Assistance) Act 1999, referred to as No Jab No Pay, and
the South Australian Public Health Act 2011, referred to as No Jab No Play.
What are the approved No Jab No Pay exemptions?
‘No Jab No Pay’ legislation approves these exemptions:
the child has a medical contraindication to a vaccine, such as anaphylaxis
the child has natural immunity to a particular disease
the child is part of an approved vaccine study
the vaccine is temporarily unavailable
the child is vaccinated overseas*, or
the Secretary (see below) has determined that the child meets the immunisation requirements.
These exemptions are applied through the Commonwealth Medicare system. They are usually applied by the child’s medical practitioner and reflected on the child’s immunisation history statement.
Parents and guardians will need to speak with their medical practitioner for exemptions to not being vaccinated are to be considered valid.
*A child vaccinated overseas will not automatically be granted an exemption; the overseas schedule for which that child was vaccinated will need to meet Australian immunisation schedule requirements. An immunisation provider will need to assess if this meets the Australian requirements and enter all doses administered overseas into the Australian Immunisation Register (AIR).
Clinical experts have determined that there are a small number of individuals who do not meet the criteria for medical exemptions as set out in the Australian Immunisation Handbook, but for whom the risks of physical harm are greater than the benefits and a process has been developed to be able to apply for an exemption.
As an example, a child with autism might require general anaesthetic to be vaccinated.
An exemption is granted if:
a listed medical practitioner has certified in writing that immunisation of the child would result in an unacceptable risk of physical harm to the child or a person administering a vaccination to the child; and
the Commonwealth Chief Medical Officer has certified in writing that he or she agrees with the listed medical practitioner.
The listed Medical Practitioners in South Australia are specific doctors that provide specialist immunology services at the Women’s and Children’s Hospital Specialist Immunisation Service Clinic. A GP referral is required to attend this clinic.
What are the South Australian Chief Public Health Officer exemptions for No Jab No Play?
Children aged less than 7 months of age are exempt from the legislation
All Aboriginal children have a 6 week temporary exemption from 17 September 2020 to Friday 13 November 2020 to enable services to request and collect records
Children who live or reside in the Anangu Pitjantjatjara Yankunytjatjara (APY) Lands are exempt from the legislation
As children come under the custody or guardianship of the Chief Executive of the Department for Child Protection as per the Children and Young People (Safety) Act 2017 a temporary exemption of six weeks will apply
As children transfer from the custody or guardianship of the Chief Executive of the Department for Child Protection pursuant to the Children and Young People (Safety) Act 2017 to another guardian or to their parent a temporary exemption of 6 weeks will apply.
Children that are Medicare ineligible – a temporary exemption of six weeks will apply from 27 August to 2 October 2020.
In special circumstances, the South Australian Chief Public Health Officer may grant an exemption.
These exemptions may be:
in relation to a specified child or a group of children; or
in relation to specified early childhood services or early childhood services of a specified group.
These exemptions may be subject to;
conditions as the Chief Public Health Officer thinks fit, and
for a specified period and vary according to the circumstances for which it applies.
A valid reason/evidence as to why a child is unable to meet all immunisation requirements, or as to why a service is unable to meet the legislative requirements, will need to be demonstrated when applying for an exemption.
Applications will not be processed if a valid reason/evidence is not supplied. A response email will be provided notifying that the application will not be processed.
When do approved immunisation records need to be supplied?
A current approved immunisation record needs to be supplied:
at the time of the child's enrolment;
after the child turns 7 months of age but before the child turns 9 months of age;
after the child turns 13 months of age but before the child turns 15 months of age;
after the child turns 19 months of age but before the child turns 21 months of age;
after the child turns 4 years and 2 months of age but before the child turns 4 years and 8 months of age.
Records must be provided at these times to show the child is up to date with all immunisations and the immunisations have been provided at the correct schedule points.
If a child enrols in or attends a service in between these specified times, then the record must be extracted no greater than one month before enrolment or attendance.
How do I check if an immunisation record, exemption notice or certificate is current?
An immunisation record provided to the early childhood service must:
at the time of enrolment, be downloaded no earlier than one month prior to enrolment; and
be downloaded within the specified age ranges (for example after the child turns 7 months of age but before the child turns 9 months of age); and
in the case of a document approved by the Chief Public Health Officer or a certificate in writing issued by the Chief Public Health Officer, be provided within the validity period of that document or certificate.
If a child is attending the service for the first time and is aged outside of the specified times when records must be provided, the record should be downloaded no earlier than one month prior to enrolment in or attendance at the service, and the record must indicate the child is on a catch up schedule, or the child's vaccinations are up to date for their age.
Who must supply the approved immunisation records?
The parent or legal guardian must supply the early childhood service with the approved immunisation records for their child.
For the purposes of this legislation, an early childhood service is a service that provides the education and/or care of children under the age of 6 years, such as childcare, family day care, occasional care, pre-school, kindergarten and early learning centres, including early childhood services provided at primary school sites.
Services such as primary education, babysitting, playgroups, childminding, or services comprising out of school care are excluded from the legislation.
The legislation does not apply to compulsory education after the child turns six years of age.
How should early childhood services collect and manage immunisation records?
Early childhood services may need to contact their approved provider, owner/operator or governing body if further assistance relating to the record management process for their service is required.
What do early childhood services need to do with the records?
Early childhood services are required to retain the provided immunisation records during the time the child is enrolled in or attends the service in accordance with their records management processes.
The records are required to be provided to the Chief Public Health Officer during an outbreak (or risk of an outbreak) of a vaccine preventable disease, on request.
What happens in the event of an outbreak of a vaccine preventable disease?
In the event of an outbreak of a vaccine preventable disease, or the risk of a vaccine preventable disease, the Chief Public Health Officer (or delegate) may request the early childhood service provider to:
provide the names and date of birth of children enrolled, or children who routinely attend the service
provide immunisation records relating to each child
provide parent or guardian contact details for each child.
Early childhood service providers must be able to provide the above details within 24 hours of a request from the Chief Public Health Officer (or delegate). This will enable the Chief Public Health Officer (or delegate) to review the immunisation status of children at the service and to exclude any child at risk of contracting the vaccine preventable disease.
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