Legislative Priority #8: Protect Texas’ Vaccine Laws, Modernize ImmTrac2
By Alisa Pierce

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Goal: Upgrade the state’s vaccine registry system to make it more user-friendly to practices.

Impact: Texas has a good set of vaccine laws in place. TMA fought for those laws over the years and will work to protect them from any erosion in a vaccine-hesitant climate so doctors can maintain the ability to continue to provide routine vaccines.

This session, TMA will focus on securing long-overdue technological upgrades to ImmTrac2, the statewide vaccine registry. A bill to do this last session died, but there is interest in resurrecting it, says TMA lobbyist Matt Dowling. And it would require only a one-time investment worthwhile for the gains of simply and accurately maintaining state vaccine data, especially coming off of a pandemic.

Physicians benefit tremendously from the real-time information ImmTrac2 provides at the point of care about a patients’ vaccine history, says Keller pediatrician Jason V. Terk, MD. He is chair of the Texas Public Health Coalition, of which TMA is member.

Texas law requires written consent to participate in the registry, and for patients who opt in, the secure and confidential database consolidates and stores immunization records. This helps physicians, health departments, schools, and other vaccine administrators know what diseases the individual is protected against, so the recommended vaccine schedule can be followed – something TMA leaders say is especially important during a vaccine-preventable disease outbreak.

But the registry is severely lacking in of technological upgrades that not only complicated physicians’ ability to use it, but also contribute to patients’ vaccine hesitancy, Dr. Terk says. He often has to remind his patients information kept in the registry is secure.

“What I would tell people who genuinely have concerns is that the data in the registry is available to only individuals who are involved in the care of a particular patient, whether it's a physician or a nurse, or sometimes a school nurse. It is a secure system that is closely cared for and guarded,” he said. “If we allow the technology of the registry to fall behind current standards, then it becomes less and less useful, and more concerns for security will rise.”

ImmTrac2 launched in 2017 with major enhancements and expanded capacity for users as a part of a Texas Department of State Health Services (DSHS) initiative to boost vaccine coverage statewide. Still, many patients do not opt-in, and many physicians struggle with its functionality and accuracy.

Among the system flaws TMA wants to see fixed:

• Automatic record destruction. Childhood vaccination records are deleted once someone turns 26 if they have not reconsented as an adult for their vaccines records to stay in ImmTrac2. Many patients are unaware of the opportunity to keep their records, and the data is lost without their knowledge.
• Consent concerns. If a patient, parent, or guardian of a minor patient chooses to withdraw from ImmTrac2, it eliminates vaccine records and proof of previous enrollment in that system. However, since consent is typically also saved in the patient’s electronic health record (EHR), they are still listed as consenting to the vaccine administrator. This means those who previously administered vaccines to the patient will not know the individual withdrew consent.
• Time consuming delays. To get a vaccine transcript, patients must either fax or mail a signed consent form or authorization to the state, versus accessing a portal to download the information themselves.

Making matters more complicated, there are six different immunization registry consent types that are not standard within common EHR software, creating challenges when exchanging patient consent and immunization data in ImmTrac2.

• Records of vaccinations given in response to a declared disaster, such as COVID-19, disappear after five years without the patient being notified, which withholds the opportunity for them to consent for their record to be retained.
• The deletion of records of immunizations administered during a disaster interferes with identifying patients who may require a booster shot in the future.
• Patients must submit a request to opt-out of ImmTrac2 by fax or mail. This process is time consuming and makes it difficult for patients to opt-out.
• Vaccination status of first responders is used to determine appropriate treatment they or their family may require after exposure. A patient can identify as a first responder only when they initially consent to ImmTrac2, meaning if they change employment or become a first responder after their consent, they may not be identified by the registry when a disaster strikes.

Mr. Dowling says there is promise for another measure like House Bill 4272, which TMA pushed for during the 2021 legislative session.

The bill by then House Public Health Committee Chair Rep. Stephanie Klick (R- Fort Worth) would have simplified the current consent options to a binary yes or no to streamline data exchange. The measure also would have aligned disaster records retention with the seven-year retention schedule for medical records as required by state law; and required DSHS to send at least two notifications about the impending deletion of a patient’s immunization record.

“We definitely have one of the most complicated systems in the country,” said Meredith Vinez TMA public health policy analyst. “Outbreak response is really handicapped by not having a system that is accessible by those who need to access it, or is inclusive of everyone who ideally would be opted into the system.”