Prepared for: Corvallis School Board

Prepared by: Ryan Noss, Superintendent

Meeting Date: October 14, 2021

Corvallis School District COVID-19 Vaccine Requirement

Executive Summary
ackground
B
The coronavirus (COVID-19) and the emerging delta variant (SARS-CoV-2) have continued to
impact in-person learning here in Corvallis, across Oregon, and in school systems across the
country. On October 14, the Corvallis School Board will explore the possibility of directing the
Superintendent to implement "all reasonable measures requiring all eligible CSD students to
receive the COVID-19 vaccine, excluding those students with quali ied exemptions under current
immunization policies, as a mandatory precondition to accessing CSD in-person programs and
facilities.”1

To see an increase in vaccination rates, community engagement will need to be culturally

responsive, linguistically appropriate, and informed by diverse perspectives from equity
populations disproportionately impacted by COVID-19.

If the School Board directs the Superintendent to implement such policy, the Superintendent
could implement a policy that requires:

● All CSD students who are 12 years of age and older and are part of in-person
instruction to be vaccinated as a irst step;
● All CSD students who are 12 years of age and older must receive by a time certain;
and
● All other CSD students must receive their irst vaccine dose following their 12th
birthday.

Key staff recommendations:

● Staff’s recommendation is for the Corvallis School Board to direct staff to conduct
community engagement by gathering feedback and information on vaccine hesitancy
among our equity populations with low vaccination rates.
● Work alongside the Benton County Health Department to engage with communities of
color to create greater con idence in the vaccine and increase vaccination rates among our
equity populations.
● Continue to provide updated data and information on COVID-19 vaccination rates among
CSD students.

1
See appendix A. Board Agenda
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● Report to the board on planning and actions related to the vaccination rate changes in our
communities of color.

Key notes of this document include:

● The coronavirus and the emerging delta variant continue to impact in-person learning
here in Corvallis, across Oregon, and for school systems across the country
● The P izer-BioNTech COVID-19 Vaccine (P izer) is currently the only FDA-approved for
emergency use treatment for children 12 to 15, and fully authorized for 16+ years of
age; although approval of the Janssen/J&J and Moderna vaccines are likely, they are not
approved under the FDA’s current Emergency Use Authorization for children 12 and
older.
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What’s in this document?

Introduction 4

Health Context 4

Emergency Use Authorization (EUA) 5

Racial Equity Implications 7

Impacts of COVID-19 on Communities of Color 7

Vaccination rates by race/ethnicity in Benton County 8

Vaccination rates by race/ethnicity in Corvallis School District 8

Community Hesitancy 10

Lead with Action: Creating access to vaccine for communities of color 10

Landscape Analysis 11

Historical Context of Vaccine Requirements in US 11

K-12 School Districts 11

Higher Education 12

Public Health Outcomes of a Vaccine Requirement 13

Current Immunization Rules in Benton County and Oregon 13

Current Vaccine Requirements for School and Child Care Attendance 13

Benton County Immunization Data 14

Existing Medical Exemption Rules 14

Existing Non-Medical Exemption Rules 14

Important Considerations 15

Expected Outcomes 15

Conclusion and Key Recommendations 16

Appendix A: Meeting Agenda 17

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Introduction
The global pandemic has been hard on all of us, especially K-12 education.

Beyond our mission to educate children, we play an important role in providing key essential
services across our communities, including after-school enrichment programs, early learning
offerings, social emotional support and counseling, and nutritious meals; all of which are key to the
vitality of communities here and across the globe.2

One of the main purposes of any required vaccination is to minimize the risk from
vaccine-preventable diseases. School vaccination requirements help safeguard children and
adolescents by making sure they are protected when they get to school. To provide the School
Board with background to help inform your decision making, below is an analysis of the potential
impacts of COVID-19 on learning and key data around COVID-19 vaccinations in CSD to consider.

Health Context
The US Food and Drug Administration (FDA) has given the P izer-BioNTech COVID-19 vaccine
emergency use authorization for children ages 12 through 15.3 The FDA has also approved this
vaccine, now called Comirnaty, to prevent COVID-19 in people aged 16 and older.

Although COVID infections among children are typically asymptomatic or mild, severe symptoms
can lead to hospitalization, with rare cases of multisystem in lammatory syndrome in children also
occurring.4 According to the American Academy of Pediatrics, although children 17 and under
appear less likely to get severely ill from COVID-19, roughly 5.5 million children in the U.S. have
contracted the virus since the start of the pandemic.

Here in Benton County, the pediatric case rate (under 18) is 566 per 100,000. There have been a
total of 641 pediatric cases for a population (0-17) in Benton County since the start of the
pandemic.5

2
United Nations Policy Brief: The Impact of COVID-19 on children (April 2020)
3
FDA: 5 Things You Need to Know about the COVID-19 Vaccine for Adolescents 12 through 17
4
COVID-19 FAQ: COVID-19 and Children
5
Benton County Public Health
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COVID-19 Pediatric Case Rate per 100,000 in Benton County

According to CSD’s COVID-19 Dashboard, there have been 56 total cases of COVID-19. Of particular
note, there have been 26 CSD students who are vaccine eligible, exposed to COVID-19, and had to
quarantine due to being unvaccinated.6 This is a signi icant burden for students who may not be
sick and may already be struggling to maintain learning.

The U.S. Food and Drug Administration (FDA) has determined that the P izer COVID-19 vaccine is
safe and effective in children aged 12 and over.7 In fact, trial data demonstrated 100% ef icacy of
the P izer-BioNTech vaccine against laboratory-con irmed, symptomatic COVID-19 in adolescents
12–15 years old. The P izer vaccine is also 91% effective in preventing severe illness with
COVID-19 in people age 16 and older.8

Over 9 million children aged 12 to 17 years old across the country are fully vaccinated against
COVID-19. Here in Benton County, 3,424 of 5,985 12-17 year olds are fully vaccinated, or 57%, and
5% of those 5,985 are partially vaccinated.9

Emergency Use Authorization (EUA)

The US Department of Justice (DOJ) issued a memorandum in July 2021, concluding that federal
law “does not prohibit public or private entities from imposing vaccination requirements for
vaccines that are subject to EUAs.”10

6
Corvallis School District COVID-19 Data
7
FDA Authorizes Pfizer-BioNTech COVID-19 Vaccine for Emergency Use in Adolescents in Another Important Action in Fight
Against Pandemic
8
Science Brief: COVID-19 Vaccines and Vaccination
9
Benton County COVID-19 Dashboard
10
Whether Section 564 of the Food, Drug, and Cosmetic Act Prohibits Entities from Requiring the Use of a Vaccine Subject to an
Emergency Use Authorization
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The vaccine developed by drugmaker P izer is the only one available to children as young as 12. In
August 2021, the Food and Drug Administration granted that vaccine full approval for use in
children 16 and older. It is authorized for the use for adolescents 12 to 15 through emergency-use.

EUA allows the U.S. Food and Drug Administration (FDA) to make a product or drug – whether new
or not yet proven for a given use – available during an emergency, provided there is data to
determine that it is reasonably safe and effective.

The basic requirements for an EUA are:

● a public health threat exists;

● there is reason to believe that the product will be effective in diagnosing, preventing, or
treating the illness;
● the known or potential bene its outweigh the risks; and
● there are no adequate, approved, available alternatives.

After determining that these vaccines meet the applicable statutory standards and the agency’s
speci ic safety and ef icacy standards, the FDA issued EUAs under Section 564 of the Federal Food,
Drug, and Cosmetic Act.11

In particular, data supporting the EUA requests show that the vaccines are effective at preventing
symptomatic COVID-19 in vaccinated individuals. Given this data, many public health experts
believe that promoting COVID-19 vaccination—along with continued engagement in community
mitigation activities that prevent transmission, such as mask wearing and social
distancing—should be a key component of any state or local government pandemic response.

Under the EUA, the FDA outlines 3 key steps to ensure the safety and ef icacy of vaccines for
children:

1. Vaccine manufacturers conduct mandatory clinical trials, allow for the proper safety
monitoring, and begin gathering necessary data. This process usually takes several months.
2. Vaccine manufacturers complete the relevant portion of their clinical trials, they have to
complete the analysis of the data from the studies to understand how safe the vaccine is
and how well it works in the clinical trial participants. The FDA works closely with
manufacturers to verify the data and indings.
3. When a completed request for EUA or approval has been received by the FDA, the agency
will carefully, thoroughly and independently examine the data to evaluate bene its/risks
and be prepared to complete its review quickly, likely in a matter of weeks rather than
months.12

P izer and BionTech recently announced positive results of COVID-19 vaccine trials in children ages
5-11.13 On October 7, 2021, P izer submitted their request to the FDA to authorize their COVID-19

11
State and Federal Authority to Mandate COVID-19 Vaccination
12
FDA Will Follow The Science On COVID-19 Vaccines For Young Children
13
Pfizer And Biontech Announce Positive Topline Results From Pivotal Trial Of Covid-19 Vaccine In Children 5 To 11 Years
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vaccine for kids aged 5-11 under EUA.14

Racial Equity Implications

We know that communities of color--in the US and globally--have been disproportionately
impacted by the health threat and subsequent consequences of the global pandemic. In fact,
COVID-19 and the public response have shone a light on what we have known: our systems are
inequitable. Policies and practices in public health and other key supports underserved and/or
exclude students and families of color.15 The public health, education, and economic uncertainties
in licted by COVID-19 are likely to exacerbate long-standing racial inequities disproportionately
affecting Black, Latino, and Native American students, English Learners, and students with
disabilities.16

In exploring increasing COVID-19 vaccinations for our equity populations through community
engagement, we must continue to amplify the voices and experiences of communities of color
and acknowledge the ways in which views of race and the impacts of racism in policies and
protocols shape experiences, beliefs and outcomes in healthcare, education, etc. As educational
systems leaders, we have the responsibility to face the institutional and cultural racism
embedded in our systems.

If we respond to the pandemic by developing race-neutral plans without addressing racial

inequities, we will deepen the divides that limit our black and brown students. Instead of
focusing on the problem, we also know that we must lead with action. Increasing accessibility to
the vaccine is not enough; we will need to consider thoughtful and proactive policy and
enactments that address vaccine hesitancy while simultaneously removing barriers.

This is achieved through deep, thoughtful, and strategic community engagement to aid in
developing positive relationships with our marginalized communities that is critical outside of
COVID-19 vaccinations. It is through listening to their voices and experiences that we begin to
understand how we can support reducing systemic inequities to COVID-19 vaccinations. We also
want to pay attention to the long history of students of color being marginalized and not
wanting to promote that further by excluding them from in-person learning due to vaccination
status.

Impacts of COVID-19 on Communities of Color

As a result of long-standing systemic health and social inequities, Black, Native American and
Latino communities are at increased risk of getting COVID-19, getting severely ill, requiring
hospitalization, and death than White communities. We all know that race and ethnicity are risk
markers for other underlying conditions that affect health, including socioeconomic status, access
to health care, and exposure to the virus related to occupation, e.g. , frontline, essential, and critical
infrastructure workers.17

14
Pfizer officially asks the FDA to authorize its COVID vaccine for kids aged 5-11
15
Harvard: Communities of color devastated by COVID-19: Shifting the narrative
16
NWEA: Learning during COVID: Initial findings on students' reading and math achievement and growth
17
CDC: Risk for COVID-19 Infection, Hospitalization, and Death By Race/Ethnicity
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Vaccination rates by race/ethnicity in Benton County 2 2

According to the last reported data on October 3, 65% of all people in Benton County are fully
vaccinated against COVID-19.

COVID-19 Vaccination Rate in Benton County 18

Vaccination rates by race/ethnicity in Corvallis School District

To better understand the vaccination rates among those in the Corvallis School District, we worked
with Benton County Health Department to review and analyze vaccination rates in our Corvallis
School District students. This allows us to more fully understand vaccination rates for students in
our schools.

Among those who are vaccine eligible in the Corvallis School district, 67.9% have been vaccinated
against COVID-19. Further broken down, this includes 65.7% of our middle school students and
69.8% of our high school students.19

18
Benton County COVID-19 Dashboard: Vaccinations
19
Corvallis School District Vaccination Data Analysis
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* These rates include students whose residence county is Benton County. 97% of CSD students live in
Benton County. These rates represent one or more doses

This data demonstrates that the populations in our district with the lowest vaccination rates are
communities of color. This indicates that, in order to improve our overall vaccination rate, any
outreach and engagement needs to be culturally responsive and linguistically appropriate, and
consider potential barriers that are driven by community trusted sources like schools and
culturally speci ic community organizations.

Community Hesitancy

We know that suspicion of the medical establishment lingers among African American, Latino and
Native communities. Furthermore, even if lingering suspicions are overcome, we know there are
multiple barriers faced by communities of color, including access to information, language barriers,
transportation challenges, paid time off to take children to obtain the vaccine, and lack of support
completing the veri ication process online.

Lead with Action: Creating access to vaccine for communities of color

Currently at CSD, students ages 12 and older and their families are eligible to receive COVID-19
vaccinations at one of our local vaccination locations. CSD is currently partnering with Benton
County Health Department to coordinate and implement COVID-19 vaccination clinics at our
facilities. This partnership includes preparation for the availability of vaccines for 5-11 year olds, to
coordinate and target roll-out of the vaccine to those CSD students once available, whether or not
vaccines are mandated.
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While we know that children primarily access vaccinations at their pediatrician’s of ice, schools
offer a unique opportunity to help get our students vaccinated for a variety of reasons:

● Trusted hubs in our community;

● Central access for all families, especially with a targeted approach for Black, Native
American, Latino and Families of Color; with special education materials and support in all
supported languages.
● Ability to support Benton County and the State of Oregon with rapidly and ef iciently
vaccinating CSD students quickly.

Landscape Analysis

Historical Context of Vaccine Requirements in US

School vaccination laws have played a key role in the control of vaccine preventable diseases in
the United States.20 The irst school vaccination requirement was enacted in the 1850s in
Massachusetts to prevent smallpox transmission in schools. By the beginning of the twentieth
century, nearly half of the states had requirements for children to be vaccinated before they
entered school.

In the early 1970s, states that mandated the measles vaccine had measles incidence rates 40% to
51% lower than states without such laws. In 1976 and 1977, measles outbreaks in Alaska and
Los Angeles, respectively, led health of icials to strictly enforce the existing requirements.
Advance notice was given that the laws were to be enforced, and major efforts were undertaken
to ensure that vaccination could be easily obtained. In Los Angeles, approximately 50,000 of 1.4
million students (4%) were excluded; most were back in school within a few days, and the
number of measles cases dropped precipitously. These experiences demonstrated that
mandatory vaccination could be enforced and was effective.

Another example of the bene its of school immunization requirements is the rollout and
implementation of the varicella vaccination.21 It was approved by the FDA in 1995. In 2008, 34
percent of eligible adolescents were fully vaccinated.22 School mandates (now in all 50 states) for
varicella vaccines were issued between 2000 and 2010.23 By 2018, about 90 percent of children
had been vaccinated against varicella.24

K-12 School Districts

Los Angeles, California (Student Population: 628,000)

20
Vaccination Mandates: The Public Health Imperative and Individual Rights
21
Approved by the FDA in 1995.
22
34 percent of eligible adolescents fully immunized by 2008.
23
School mandates (now all 50 states) for Varicella vaccination issued between 2000 and 2010.
24
Vaccination coverage for selected diseases among adolescents aged 13–17 years, United States, selected years 2008–2018
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Los Angeles Uni ied is one of the nation’s largest school districts with more than 628,000 students
spread across 710 square miles. Los Angeles Uni ied became the irst major school district in the
nation to require COVID vaccines for students on September 18 through its Safe Steps to Safe
Schools policy adopted by the LAUSD Board of Education.25 LAUSD employs a 5-step process to
verify a student’s vaccination status through an online portal system.26

Students must receive the P izer vaccine if they are under the age of 18. As with other
immunizations for students, California law does not recognize religious or personal belief
exemptions.27

Beginning Monday, January 10, 2022, eligible students who do not have proof of vaccination against
COVID-19 will be offered the District’s independent study program, unless the student has a
quali ied exemption or conditional admission. Children who are not vaccinated after October 31,
2021 will not be permitted to participate in in-person extracurricular activities without proof of
vaccination if they qualify to receive it.

Oakland, California (Student Population: 52,167)

In a 5-1-1 vote taken on September 22, the Oakland school board decided that students 12 and
older must be vaccinated “unless prohibited by law.” The district still needs to determine when the
mandate should take effect and how it will be enforced. Board members directed Superintendent
Kyla Johnson-Trammell to return next month with recommendations.28

San Diego, California (Student Population: 122,916)

The San Diego Uni ied School District currently requires students and staff to show proof of
vaccination or get tested weekly in order to attend or work in person. The Board of Education is
considering a staggered approach to have all eligible students vaccinated against COVID-19, as a
condition of attending in-person learning. The timeline for requiring the mandated vaccination will
be aligned to the full FDA approval. Mandatory testing will be required for all unvaccinated students
until full FDA approval of the vaccine for their age group.29

Higher Education

regon State University

O
Oregon State University requires all students to receive the COVID-19 vaccine. Like other K-12
and post-secondary institutions, the university allows for speci ic exemptions for medical and
non-medical reasons. Students who request an exemption are required to take part in weekly
COVID-19 testing, along with students who are in the process of becoming fully vaccinated, until

25
Los Angeles Unified to Require All Students 12 and Older to be Vaccinated Against COVID-19 by January 10, 2022
26
LAUSD: Uploading External COVID-19 Vaccination Record
27
LAUSD Safe Steps to Safe Schools FAQ
28
OUSD Board of Education Passes Vaccine Requirement for Students 12 Years Old and Up
29
SD Unified School District Vaccine Roadmap
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they are fully vaccinated - 2 weeks after their last dose.30

The university also requires proof of vaccination for children 12 and older for designated
university events and activities. For those who cannot provide proof of vaccination,
documentation of a negative test taken within three days of the event will also be accepted.
31

Public Health Outcomes of a Vaccine Requirement

We love that our schools serve as learning hubs for our entire community. We will partner with
public health agencies to educate and promote COVID-19 vaccinations and other health and
safety measures to protect against COVID-19. As guidance evolves, we will keep the board and
families up to date on the latest information.

Current Immunization Rules in Benton County and Oregon

Current Vaccine Requirements for School and Child Care Attendance

Oregon law requires the following vaccinations for school and child care attendance. At all
ages and grades, the number of doses required varies by a child’s age and how long ago they
were vaccinated. Other vaccines may be recommended.32

A child 18 months or older entering Preschool, Child 4 Diphtheria/Tetanus/Pertussis (DTaP)

Care, or Head Start needs 3 Polio
1 Varicella (chickenpox)
1 Measles/Mumps/Rubella (MMR)
3 Hepatitis B
2 Hepatitis A
3 or 4 Hib

A student entering Kindergarten or Grades 1-6 needs 5 Diphtheria/Tetanus/Pertussis (DTaP)

4 Polio
1 Varicella (chickenpox)
2 MMR or 2 Measles, 1 Mumps, 1 Rubella
3 Hepatitis B
2 Hepatitis A

A student entering Grades 7-12 needs 5 Diphtheria/Tetanus/Pertussis (DTaP)

1 Tdap
4 Polio
1 Varicella (chickenpox)
2 MMR or 2 Measles, 1 Mumps, 1 Rubella
3 Hepatitis B
2 Hepatitis A

30
Oregon State University: Vaccination Program Requirement
31
Oregon State University: Event Vaccination Requirement
32
2021-22 Immunization Requirements
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Benton County Immunization Data

According to Benton County Public Health 92% of all school-aged kids are currently in
compliance with all immunization requirements. Percentage ranges between 94% and 97%
with speci ic immunization requirements.33

Existing Medical Exemption Rules

Oregon allows medical exemptions for children who have a medical condition that contraindicates
vaccination. Only physicians or local health departments may sign a medical exemption. Children
with this type of medical exemption are considered susceptible because if they are exposed to a
disease they haven’t been vaccinated for, they are more likely to get it.

Medical exemptions must be in a letter from a physician or local health department

supplementing the Certi icate of Immunization Status. The letter must include the child’s name
and birth date, vaccine(s) affected, the condition that contraindicates vaccination as well as the
physician’s or local health department representative’s signature and contact information.

In case of an outbreak of vaccine-preventable disease in a community, the local health department

has the legal authority to exclude from school or child care attendance any child who has not been
completely immunized, including children with a medical exemption.34

Existing Non-Medical Exemption Rules

Oregon recognizes exemptions for nonmedical reasons. However, OHA allowed colleges and
universities to decide whether to allow philosophical exemptions related to COVID-19. Oregon

33
Benton County Health Department: 2021 Immunization Data
34
MESD Medical Exemptions
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State University, for example, allows students and employees to seek an exemption for medical,
religious, philosophical or other non-medical reasons. Those with an exemption are required to
take part in weekly testing.

To claim a nonmedical exemption for immunizations required for schools, a parent must submit a
Vaccine Education Certi icate from a healthcare practitioner or from the online education module
to the child’s school or childcare. In addition, the parent must check the appropriate boxes and
sign the back of the Certi icate of Immunization Status, available from the child’s school or
childcare facility. Listing a vaccination history on the front of the Certi icate of Immunization
Status will not affect a parent’s ability to claim an exemption. In case of an outbreak of
vaccine-preventable disease in a community, the local health department has the legal authority to
exclude from school or child care attendance any child who has not been completely immunized,
including children with a nonmedical exemption.

Important Considerations

Expected Outcomes

Short-Term

● Increase the number of children and their families who are vaccine hesitant to participate in
community engagement, increase their knowledge about COVID-19 vaccines, and increase
their con idence in the ability of the Corvallis School District and public health to be a
trusted resource in the community.

Intermediate

● Among those not currently vaccinated, a reconsideration and subsequent increase in

vaccination rates will limit the number of students who need to quarantine if possibly
exposed to a case of COVID-19, increasing our ability to keep students attending in-person
instruction.

Long-term

● Personal, direct, protection against disease for students.

● Reduce the number of CSD students who are vaccine eligible that are required to quarantine
when exposed.
● CSD is able to provide uninterrupted full-time in-person instruction.
● Positive relationship with marginalized communities that extends beyond COVID-19
vaccinations.
● The potential to generate herd immunity, a form of indirect protection from infectious
disease that can occur if a suf icient percentage of a population has become immune to an
infection.
● Reduce immense pressure on our healthcare system.
● While over 60% of the adolescents (12-17 years of age) in the Corvallis School District are
vaccinated against COVID-19, this creates an additional layer of protection for all that attend
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school in Corvallis, including staff, volunteers and students too young to be vaccinated.

Conclusion and Key Recommendations

1. Staff Recommends Community Engagement

Staff’s recommendation is for the Corvallis School Board to direct staff to conduct
community engagement by gathering feedback and information on vaccine hesitancy among
our equity populations with low vaccination rates.

2. CSD (and Public Health) Communication and Engagement Strategy

Work alongside the Benton County Health Department to engage with communities of color
to create greater con idence in the vaccine and increase vaccination rates among our equity
populations.

3. Continued monitoring of COVID-19 Vaccination Rates

Continue to provide updated data and information on COVID-19 vaccination rates among
CSD students.

4. Vaccination Rate in Equity Populations

Report to the board on planning and actions related to the vaccination rate changes in our
communities of color.
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Appendix A: Meeting Agenda

SD School Board of Education Meeting:
C
Possibility of a COVID-19 Vaccination for Students
October 14, 2021

urpose:
P
Corvallis School Board will discuss a possible mandate for a COVID vaccine for students and
the impacts of implementing such a vaccine.

genda:
A
Opening Remarks | Ryan Noss, Superintendent

Introduction and Opening Remarks | Panelists

Board Discussion and Questions (30 Minutes)

Board Direction to Superintendent | Board Chair

Invited Panelists:
● April Holland, Public Health Administrator, Benton County Health Department
● Peter Banwarth, Epidemiologist, Benton County Health Department
● Dr. Adam Brady , Infectious Disease Specialist, Samaritan Health Services
● Dr. Carolina Amador , Pediatrician, Lincoln Health Center
● Dr. Bruce Thomson , Health Of icer, Benton County Health Department