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FAX 202 456 5581 DOMESTIC POLICY COL 001 The White House the DOMESTIC POLICY FACSIMILE TRANSMISSION COVER SHEET TO: Nicole Rabner FAX NUMBER: 62878 TELEPHONE NUMBER: 62263 FROM: Essence Washington TELEPHONE NUMBER: - 67732 PAGES (INCLUDING COVER): 4 COMMENTS: Today Conference Call Material 11:30AM 66766 # 4441 09/15/97 JION 10:52 FAX 202 456 5581 DOMESTIC POLICY COL 002 United States Department of State Washington, D.C. 20520 Dear Mr. Nadler: This letter is to respond to your request for the views of the State Department on draft legislation exempting immediate relative immigram orphans from the vaccination requirement imposed in Section 212(a)(1) of the Immigration and Nationality Act. I The proposed language will accomplish the objective of exempting immediate relative immigrant orphans from the vaccination requirement It will not impose any operational difficulties on overseas consular operations and will not require any additional expenditure of resources. while we Are supportive of this exemption, Although the Department does not express any opinion as to whether this logislation in needed, R'C do wish to point OUR that while 12,000 children are expected TO immigrate as immediate relative immigrant orphans, an additional 28,000 children are expected 10 insulgrate as non-orphan children of American citizons. The Department estimates that a further 50,000 children will immigrate in other categories or as dependents of their immigrant parents. Under these circumstances the Department would expect that some members of the public will question the equity of exempting only immediate relative immigrant orphans and not these other children )-ducto? 1 The Clinton Administration maintains a strong commitment and record to promoting adoption and supporting measures to ease the foreign adoption process. Itshould be noted that 2 Many of The health concerns raised by the adoption community regarding the vaccination requirement to other children have broader applicability categories as well migrating we hope we in can other The Honorable, Jerrold Nadler, work with The committees to House of Representatives. address some of these issues. 09/15/97 MON 10:53 FAX 202 456 5581 DOMESTIC POLICY COL 003 2 The Office of Management and Budget advises that from the standpoint of the Administration's program, there is no objection to this language. I hope this information is useful to you. Please do not hesitate to contact me if you have additional questions. Sincerely, Barbara Larkin Assistant Secretary Legislative Affairs 09/15/97 MON 10:53 FAX 202 456 5581 DOMESTIC POLICY COL 4 004 SECTION 1. EXCEPTION FROM VACCINATION REQUIREMENT. Section 212(a)(1) of the Immigration and Nationality Act (8 U.S.C. 1182(a)(1)) is amended-- (1) in subparagraph (A)(ii), by inserting `except as provided in subparagraph (C),' after `(ii)'; and (2) by adding at the end the following: `(C) EXCEPTION FOR ADOPTED CHILDREN- Subparagraph (A)(ii) shall not apply to a child who is-- (i) described in section 101(b)(1)(F); (ii) seeking an immigrant visa as an immediate relative under section 201(b); and (iii) 10 years of age or younger at the time 8 petition is filed in the child's behalf to accord a classification as an immediate relative under such section.'. SEP-09-1997 08:11 TO:N RABNER FROM:GAYMON, D. P. 2/5 LRM ID: IMS138 SUBJECT: OMB Report on HR2267 Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations, FY 1998 RESPONSE TO LEGISLATIVE REFERRAL MEMORANDUM If your response to this request for views Is short (e.g., concur/no comment), we prefer that you respond by e-mail or by faxing us this response sheet. If the response is short and you prefer to call, please call the branch-wide line shown below (NOT the analyst's line) to leave a message with a legislative assistent. You may also respond by: (1) calling the analyst/attorney's direct line (you will be connected to voice mail if the analyst does not answer); or (2) sending us a memo or letter Please include the LRM number shown above, and the subject shown below. TO: Ingrid M. Schroeder Phone: 395-3883 Fax: 395-3109 Office of Management and Budget Branch-Wide Line (to reach legislative assistant): 395-3454 FROM: 9/10/97 (Date) Nicole Rabner /Jennifer (Name) DPC (Agency) 456-7263 (Telephone) The following is the reponse of our agency to your request for views on the above-captioned subject: Concur No Objection No Comment 1 See proposed edits on pages Other: FAX RETURN of 1 pages, attached to this reponse sheet SEP-09-1997 08:11 TO:N RABNER FROM: GAYMON, D. P. 3/5 United States Department of State Washington, D.C. 20520 Dear Mr. Nadler: This letter is to respond to your request for the views of the State Department on draft legislation exempting immediate relative immigrant orphans from the vaccination requirement imposed in Section 212(a)(1) of the Immigration and Nationality Act. The proposed language will accomplish the objective of exempting immediate relative immigrant orphans from the vaccination requirement. It will not impose any operational difficulties on overseas consular operations and will not require any additional expenditure of resources. Although Ox the Department However, does not express any opinion as to whether this particular legislation is needed, we do wish to point out that while 12,000 children are expected to immigrate as immediate relative immigrant orphans, an additional 28,000 children are expected to insulgrate as non-orphan children of American citizens. The Department estimates that a further 50,000 children will immigrate in other categories or as dependents of their immigrant parents. Under these circumstances the Department would expect that some members of the public will question the equity of exempting only immediate relative immigrant orphans and not these other children. The Clinton Administration maintains a strong 1 commitment to promoting adoption and supporting a doptive parents. While the Clinton Administration supports measures to ease the foreign adoption process, 2 The Honorable, Jerrold Nadler, House of Representatives. 1 SEP-09-1997 08:11 TO:N RABNER FROM GAYMON, D. P. 1/5 Total Pages: LRM ID: IMS138 EXECUTIVE OFFICE OF THE PRESIDENT OFFICE OF MANAGEMENT AND BUDGET Washington, D.C. 20503-0001 Monday, September 8, 1997 LEGISLATIVE REFERRAL MEMORANDUM TO: Legislative Liaison Officer - See Distribution below FROM: James J. Jukes (for) Assistant Director for Legislative Reference OMB CONTACT: Ingrid M. Schroeder PHONE: (202)395-3883 FAX: (202)395-3109 Ji- SUBJECT: OMB Report on HR2267 Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations, FY 1998 DEADLINE: Noon Tuesday, September 9, 1997 In accordance with OMB Circular A-19, OMB requests the views of your agency on the above subject before advising on its relationship to the program of the President. Please advise us If this item will effect direct spending or receipte for purposes of the "Pay-As-You-Go" provisions of Title XIII of the Omnibus Budget Reconciliation Act of 1990. COMMENTS: State Department advises that the vaccination amendment (referenced in the letter) may be added to H.R. 2267 during House floor consideration, which may begin as early as 9/9/97. DISTRIBUTION LIST AGENCIES: 52-HHS Sondra S. Wallace - (202) 690-7760 61-JUSTICE - Andrew Fois - (202) 514-2141 83-National Security Council - Glyn T. Davies - (202) 456-9221 EOP: Steven M. Mertens Joseph G. Pipan Evan T. Farley N- Nicolette Highsmith Robert J. Pellicci Debra J. Bond Can you call Andrew Abrams Robert E. Barker mi about this? Leanne A. Shimabukuro Jose Cerda III WARNATH_S J Scott Busby Jennifer L. Klein Nicole R. Rabner Charles E. Kieffer SEP-09-1997 08:11 TO:N RABNER FROM: GAYMON, D. P. 4/5 2 The Office of Management and Budget advises that from the standpoint of the Administration's program, there is no objection to this language. I hope this information is useful to you. Please do not hesitate to contact me if you have additional questions. Sincerely, Barbara Larkin Assistant Secretary Legislative Affairs SEP-09-1997 08:11 TO:N RABNER FROM:GAYMON, D. P.5/5 servi 01:33:37 96472762 P.03 H.I.C. AMENDMENT TO H.R. 2267, AS REPORTED Complete BY MR. NADLER OF NEW YORK Page 38, after line 11, insert the following new sec- tion: 1 EXCEPTION FROM VACCINATION REQUIREMENT FOR 2 ORPTIAN CITILDREN 3 SEC. 110. Section 212(a)(1) of the Insurigration and 4 Nationality Act (8 U.S.C. 1182(a)(1)) is amended- $ (1) tn subperagraph (A)(ii), by inserting "ex- 6 cept as provided in subparagraph (C) after "(ii)", 7 and 8 (2) by adding at the end the following new sub- 9 paragraph: .10 "(C) EXCEPTION FOR ORDIAN CHIL- 11 DREN.-Clause (ii) of subparagraph (A) shall 12 not apply to a child who is described in section 13 101(b)(1)(F) and is seeking an Sumigrant visa 14 as as Immediate relative under section 15 201(b).". August 20. ar. 1897 (Sult a.m.) AFL/CIO-ECON RES-DEPT ID:2025086967 SEP 04'97 16:52 No. 024 P.01 nicality fach breaker his FAX TRANSMISSION AFL-CIO + 015 OTH STREET, N.W., ROOM 504 WASHINGTON, D.C. 20006 (202) 637-5178 FAX: (202) 508-6967 To: Melanne Verveer Date: Sept. 4, 1997 Fax #: 202-456-6244 Pages: 4 including this cover sheet. From: Christine L. Owens Subject: AFL-CIO Child Care Initiative COMMENTS: Following up on the meeting you had with Karen and me a few weeks ago about a possible AFL-CIO Child Care Initiative, I am forwarding a copy of the press release we issued today, in advance of tomorrow's Ask A Working Woman Conference. The final page includes statements from President Sweeney to the effect that expanding the nation's supply of affordable, accessible and high quality child care will be a new priority for the AFL-CIO, and committing the AFL-CIO to work at the national and local levels to achieve this goal. AFL/CIO-ECON RES-DEPT ID 2025086967 SEP 04'97 16:52 No. 024 P.02 WASHINGION, 20008 202-637.5064 FAX 202-508-6902 WORKING WOMA AFLECIO WORKING NEWS RELEASE TOGITHER CONTACT: Lisa Lederer September 4, 1997 Gretchen Wright 202/371-1999 Deborah Dion 202/637-5036 FIRST PUBLIC OPINION SURVEY TO EXPLORE WOMEN'S VIEWS SINCE THE ECONOMIC RECOVERY FINDS FAIR PAY, JOB SECURITY AMONG WOMEN'S TOP PRIORITIES AFL-CIO Launches Working Women Working Together Network WASHINGTON, DC -- Working women say that, despite the economic recovery, making ends meet has become more difficult in the last five years and their job security is getting worse rather than better. Those are among the findings of a major new study released today by the AFL-CIO. Part of an unprecedented outreach campaign run by the AFL-CIO Working Women's Department, the Ask A Working Woman study supplemented a popular survey that was returned by 50,000 working women with a scientific telephone survey of 725 working women that was conducted by the public opinion research firm of Lake, Sosin, Snell, Perry and Associates July 30 to August 3, 1997. Nearly two-thirds of working women say they provide "about half or more" of their household income, according to the scientific survey. Equal pay is a top concern for working women, and time and respect are scarce commodities. The survey found that, by an overwhelming margin, women believe that joining together to work for change in the workplace is more effective than working individually for change. "Sixty-one million American women work for pay, and their families rely on their paychecks," AFL-CIO President John Sweeney said in releasing the study. "By overwhelming margins, working women told us they want paychecks that let them make ends meet, better benefits and security, and respect on the job. The economic recovery alone will not solve these issues for working women. We intend to do even more organizing to address their concerns." The scientific survey, which included oversamples of African American, Hispanic and Asian American working women, found that: Sixty-four percent of working women, 52 percent of married working women and 40 percent of part-time women workers provide about half or more of their household income. Two in five working women (41 percent) head their households. more to join the Working Women Working Together Network call toll-free 1-888-971-9797 AFL/CIO-ECON RES-DEPT ID:2025086967 SEP 04'97 16:53 No. 024 P.03 Add One More women (37 percent) say that making ends meet has become more difficult in the last five years than say that it has gotten easier (29 percent). Nearly every working woman (99 percent) cites equal pay for equal work as important. Yet, nearly one-third of women workers (32 percent) say that their own job does not provide equal pay for equal work. Half of African American (50 percent) and two in five clerical and secretarial women workers (42 percent) say they do not have equal pay for equal work right now. Nine in ten working women (92 percent) say protection from lay-offs and down-sizing is important. Yet, just one in three respondents (34 percent) say they are protected from layoffs in their current jobs. Forty-one percent say job security has gotten worse for women in the last five years, while just 26 percent say it has gotten better. Many more union (55 percent) than non-union women (32 percent) say their current job is secure. Eighty-two percent of working women say sick leave is important to them, but three in ten (29 percent) do not have paid sick leave. Sixty-two percent of working mothers with children under age six say child care is "very A important" to them. Just 13 percent of these mothers have jobs that provide child care. African American and Hispanic women are most likely to want and not have child care. Three in four working women (78 percent) say that punishment for sexual harassment is very important to them. Yet, 35 percent say this protection is not provided by their employer today. Four in five respondents (79 percent) say the best way to solve workplace problems is for women to "join together and work as a group" rather than to "work separately as individuals." At least three in four working women want employers, working women's organizations, government, community and civic groups, and labor unions to help solve the problems they face'at work. In addition to the scientific and popular surveys, the Ask A Working Woman campaign included meetings around the country with working women. Designed to listen to working women, the meetings featured a single mother who works the night-shift at a factory in Maine, hotel workers in Honolulu describing their struggles to meet family and work demands, flight attendants in Atlanta describing how they are treated on the job. and much more. The popular survey was distributed at worksites, grocery stores, beauty parlors, soccer games, prayer breakfasts, and other places where women gather. To address the other issues women raised, the AFL-CIO launched a new Working Women Working Together Network. Already 50,000 members strong, the Network will work to organize at the local, state and federal levels, press for passage of legislation of concern to women, and promote women's involvement in elections at every level of government. Women can join the Working Women Working Together Network by calling toll free, 888/971-9797. more AFL/CIO-ECON RES-DEPT ID:2025086967 SEP 04'97 16:54 No. 024 P.04 Add Two "Our goal is to start a national conversation on working women's issues," AFL-CIO Working Women's Department Director Karen Nussbaum said. "Working women face deadlines at home and at work. A sick child or a demanding boss. A new muffler or the electric bill. Through this initiative, working women have expressed their priorities. They want pay and protection, benefits and economic security, and control of their time. The AFL-CIO stands ready to respond." AFL-CIO Vice President and Chair of the Committee on Women Workers Gloria Johnson said the union will launch a new campaign to promote equal pay for women. "Equal pay is women's top concern, and we will respond with a grassroots campaign that makes women's wages the public issue it deserves to be," Johnson said. "Each woman should not have to fight individually for fair pay. The system needs to treat women fairly. Women can call 888/971-9797 for information on how to fight for equal pay." The AFL-CIO will also plan local actions on fair pay, and press for passage of two bills now before Congress -- the Fair Pay Act and the Paycheck Fairness Act. The AFL-CIO also announced that expanding the nation's supply of high quality, affordable, and accessible child care will be a priority. "Working parents tell us they need safe, affordable, and + convenient child care," Sweeney said. "Unions have worked hard to provide that to our members. But the labor movement's commitment is to all of the nation's children and to all working parents. That is why we are expanding our child care focus." The AFL-CIO's child care program will combine support for greater federal funding for child care with local union activity to promote and shape new community-based initiatives designed to increase supply, set high standards, and raise providers' pay. Expanding the supply of school age care will be a priority. Today, seven out of ten public schools offer no pre- or after-school child care programs. After-school care also can provide educational help, including tutoring in kcy subjects. To be effective, such educational programs need to be staffed by qualified personnel, related to the regular school program, and make use of educational programs known to work. "We will be working to secure both adequate funding and standards of quality for such programs," Sweeney said. A Working Women Working Together conference with more than 1,500 working women from around the country will be held September 5 7 in Washington, D.C. Speakers will include Vice President Al Gore, U.S. Secretary of Labor Alexis Herman, U.S. Senator Barbara Mikulski (D- MD), former Texas Governor Ann Richards, AFL-CIO President John Sweeney, and other Members of Congress and high-ranking labor officials. Plenary and workshop topics will address living wage campaigns, pay equity, flextime and flexible hours, bargaining for work and family issues, child and elder care, sexual harassment, workplace safety, welfare reform, organizing health care providers, and much more. The conference is open to the mcdia. AFL-CIO President John Sweeney created the Working Women's Department last year. Women make up almost one-half the workforce today, and their numbers are increasing. Ninety- nine percent of women in the U.S. will work for pay at some time in their lives. The AFL-CIO is the nation's largest working women's organization with 5.5 million women members. -30- NOTE: Copies of the Ask A Working Woman study are available to the media from Lisa Lederer or Gretchen Wright at 202/371-1999. The report is available to the public from the AFL-CIO Working Women's Department at 888/971-9797. State Department letter to Hon. Jerold Nadler Re: Exemption from Vaccination Requirement for Immigrating Adoptive Children PARAGRAPH 3: Strike language until "we do wish" on line 2 Begin with: Adm /Ctinto measures to ease ne 6 The Clinton Administration maintains a strong commitment to promoting adoption and supporting adoptive parents. While the Department is supportive of the intent of this legislation to ease the foreign adoption process, the Department does-not express any opinion as-to whether-- this legislation is needed, However, do wish [continue language] particular R Jen- 1.9 - med pro. what do you think? 2. equity Lets descuss; its tricky. 2 Nok -> for disassion purposes. WED 11:33 FAX 202 456 5581 DOMESTIC POLICY COL 001 The White House DOMESTIC POLICY FACSIMILE TRANSMISSION COVER SHEET TO: Niwle Rabner FAX NUMBER: 69412 TELEPHONE NUMBER: FROM: learn Shimatuken TELEPHONE NUMBER: PAGES (INCLUDING COVER): COMMENTS: 09/10/97 WED 11:34 FAX 202 456 5581 DOMESTIC POLICY COL 002 WORKING DRAFT -- 8/22/97 Chronology/Summary/Purpose of Amendment Summary of Overall Purpose The purpose of this amendment is to address the growing public health problem In the United States by ensuring proper medical screening of arriving immigrants, and by educating arriving immigrants on the importance of vaccinations. This public education effort hopes to achieve the same success enjoyed by the vaccination program in the United States. Chronology December 1995: In December 1995, INS, DOS, HHS and CDC met with the subcommittee members to discuss section 154 in S. 1664, which created a new medical ground of inadmissibility under section 212 of the Act relating to vaccinations. April 1996: The agencies expressed serious concerns about the vaccination requirements as a new medical ground of inadmissibility. The Administration was particularly concerned about certain implementation and other difficulties that may actually jeopardize the public health in the United States. An excerpt of the views letter submitted to Senator Bob Dole dated April 16, 1996, is attached. May 1996: The Administration drafted an alternative amendment, which was offered on the Senate floor and adopted in Section 154 of S. 4743. A copy of the relevant excerpt from the Congressional Record dated May 6, 1996 is attached. The amendment offered by the Administration took the vaccination requirements out of section 212 of the Act, where they would be a ground of inadmissibility, and put them in section 234 (subsequently redesignated as section 232(b) by the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA)). The idea was to ensure proper medial screening of arriving aliens, by incorporating a vaccination assessmentint the medical examination process and educating arriving aliens on the importance of vaccinations, and by creating a new medical examinations fee account to be used for training and overseeing the physicians who conduct the medical examinations. Under the amendment passed in S. 4743, the vaccination assessment was to be incorporated into the existing medical examination requirements, and was to include a review of the alien's record of vaccination against mumps, measles, rubella, polio, tetanus, diphtheria toxoids, pertussis, Hemophilus-influenzae type b, hepatitis B, any other vaccines recommended by the ACIP. The new Medical Examinations Fee Account was intended to provide a direct funding mechanism to cover the cost of creating viable civil surgeon programs (for medical examinations performed in the United States) and panel physician programs (for medical examinations performed abroad), 09/10/97 WED 11:34 FAX 202 456 5581 DOMESTIC POLICY COL 003 009 08/25/97 13:31 202 842 9220 HQIRT which includes, but is not limited to, training and quality control.¹ The fee account was to be funded through fees imposed by INS on adjustment of status applications field in the U.S. and by DOS on visa applications filed at U.S. consular posts abroad. The fee was to be determined by the Department of Health and Human Services, and was to be collected when the Attorney General conferred upon the Secretary of HHS the authority to designate the civil surgeons who perform the required medical examinations in the U.S. The approach taken in section 154 of S. 4748 was one of public education, because the public education approach taken towards vaccination programs in the U.S. had been so successful. [MAYBE HHS CAN ADD A BLURB HERE]. September 1996: The vaccination provisions in the final legislation, section 341 of IIRIRA, did not adopt the approach taken in section 154 of S. 4743. The vaccination requirements were retained in section 212 of the Act, which makes them a medical ground of inadmissibility. The fee account, which was needed to delegate to CDC the authority to oversee the civil surgeon and panel physician programs, also was not adopted. March 1997 - Present: The adoption advocacy groups vehemently protested the vaccination requirements adopted in the final legislation because of the following concerns, which include: The accuracy of health records of orpahn children living in orpahnages The potential use of unsterilized needles Adverse reactions to live virus vaccines resulting from malnutrition, or bad vaccines CDC published a study on TB in the April 1995 issue of the New England Journal of Medicine This study reported an increase of TB among the foreign born population living in the United States from 21.6% in 1986 to 29.6% in 1993. This study also called for "major improvements" in TB screening, to include improvements in the medical screening process. The underlying problem, however, lies in existing law. The law currently states that PHS medical officers should perform the medial exam, and that in the absence of available PHS medical officers, INS сап designate civil surgeons who have at least 4 years of experience. Because PHS medical officers have not been available since the early 1970s (only 8 U.S. ports of entry are staffed by PHS medical officers), INS became responsible for designating the civil surgeons in the United States and for monitoring their activities. (Panel physicians performing the medical screening abroad are designated by DOS consular officers in consultation with CDC). Because of the dramatic increase of the number of designated civil surgeons in the United States, the resurgence of TB, and the emergence of HIV and AIDS, the need for enhanced quality control over the medical examination process is absolutely essential. INS, however, lacks the needed medical expertise. Provisions for a special CDC medical exam fee account were therefore included in the legislation so that the necessary funds can be made available for HHS/CDC to oversee the designated civil surgeons in the United States and the panel physicians abroad. This measure, in turn, will contribute immensely to the effort to curtail the spread of TB in the United States, and to public health in general. -2- 09/10/97 WED 11:35 FAX 202 456 5581 DOMESTIC POLICY COL 004 08/25/97 13:32 202 842 9220 HQIRT 010 Inability to test children for immune dysfunctions while abroad Lack of informed consent for vaccines. The panel physician may not be a pediatrician and may not realize that the child is immunocomrpmised. The Administration's Concerns About the McCain and Kyl Amendment No. 1015 The McCain-Kyle Amendment proposes to amend section 212 of the Act to add a new paragraph (p) stating that the attorney General should exercise the waiver authority provided in subsection (g)(2)(B) for any alien orphan applying for an IR3 or IR4 category visa. The administration has concerns with this amendment, because section 212(g)(2)(B) of the Act provides that the Attorney General may waive the requirement for one or more of the specified vaccines when the panel physician or civil surgeon or panel physician certifies, in accordance with HHS regulations, that the vaccine would not be medically appropriate. The McCain-Kyle amendment is directing the Attorney General to exercise discretion in IR3 and IR4 orphan cases independently of the examining physician. All findings of inadmissibility on medical grounds, however, are made by the Attorney General based on the information provided by the examining physician. The examining physician, in turn, must prepare that information according to the specific regulations prescribed by HHS. The Attorney General, therefore, cannot and should not second-guess the findings made by the medical experts. the Attorney General does not have the medical expertise needed to make independent medical assessments. Moreover, the McCain-Kyle amendment covers only orphans and not other children or adults who might be exposed to the same potential dangers as orpahns, such as live vaccines and unsterile needles. Purpose and Scope of the Administration's Proposed Amendment The Administration appreciates the concerns about the current vaccination requirements raised by the adoption advocacy groups but wishes to point out to Congress that the issues are not only of concern to orphans, but to all children, and even to adults in some cases. For these reasons, the Administration would favor legislation that would not only promote vaccinations in a positive way, by encouraging arriving immigrants to participate in the system, but also address other health concerns, such as TB and the need to assure adequate quality control measures in the overall medical examination process. [HHS SHOULD ADD HERE WHY THE ENFORCEMENT MEASURES CALLED FOR IN PENDING LEGISLATION WOULD NOT BE AS EFFECTIVE AND DESIRABLE AS THE PUBLIC EDUCATION EFFORTS PRESCRIBED BY THE ALTERNATIVE AMENDMENT RECOMMENDED BY THE ADMINISTRATION. CITE SUCCESS OF U.S. VACCINATION PROGRAM, I.E., RECENT WHITE HOUSE ROLL-OUT OF VACCINATION STATISTICS, RECORD HIGH NUMBER OF DOMESTIC VACCINATIONS, THAT SUCCESS OF THE PROGRAMWAS DUE IN LARGE PART TO AN EXTENSIVE PUBLIC EDUCATION EFFORT, AND THAT THIS IS WHAT WE HOPE TO DUPLICATE HERE IN THE ALTERNATIVE AMENDMENT OFFERED.] -3- 09/10/97 WED 11:36 FAX 202 456 5581 DOMESTIC POLICY COL 005 WORKING DRAFT #2 8/21/97 Sec. VACCINATION REQUIREMENTS FOR IMMIGRANTS (a) Section 212(a)(1)(A) of the Immigration and Nationality Act (8 U.S.C. 1182(a)(1)(A)) is amended-- (1) by striking clause (ii); and (2) by redesignating clauses (iii) and (iv) as clauses (ii) and (iii), respectively. (b) Section 212(g) of the Immigration and Nationality Act (8 U.S.C. 1182(g)) is amended-- (1) by striking paragraph (2); and (2) by redesignating paragraph (3) as paragraph (2). (c) Section 232 of the Immigration and Nationality Act (8 U.S.C. 1252) is amended-- (1) by revising the title of section 232 to read "PHYSICAL AND MENTAL EXAMINATION OF ALIENS"; and "(2) by amending paragraph (b) to read as follows: "(b) Physical and Mental Examination of Aliens.-- "(1) ALIENS COVERED.-- Each alien within any of the following classes of aliens who is seeking admission into the United States shall undergo a physical and mental examination in accordance with this subsection and section 221(d) of this Act: "(A) Aliens applying for visas for admission to the United States for permanent residence; "(B) Aliens seeking admission to the United States for permanent residence for whom examinations were not made under paragraph (1) of this subsection; "(C) Aliens within the United States seeking adjustment of status under section 209, 210, 09/10/97 WED 11:36 FAX 202 456 5581 DOMESTIC POLICY COL 006 residence; and "(D) Any other alien or class of aliens, including alien crewmembers, applying for a visa, seeking admission to or transiting the United States, applying for an immigration benefit or in detention in the United States, for whom the Anomey General, the Secretary of State, or the Secretary of Health and Human Services requires an examination. "(2) DESCRIPTION OF EXAMINATION.- (A) Each examination required by paragraph (1) of this subsection shall include-- "(i) An examination of the alien for any physical or mental condition that is a ground of inadmissibility under section 212(a)(1)(A) of this Act; and "(ii) An assessment of the vaccination record of the alien in accordance with paragraph (5) of this subsection. "(B) The Secretary of Health and Human Services shall prescribe such regulations as may be necessary to carry out the medical examinations required by paragraph (1) of this subsection. "(3) MEDICAL EXAMINERS.- "(A) MEDICAL OFFICERS.- (i) Except as provided in subparagraphs (3)(B) and (C) of this subsection, the medical examinations shall be conducted by medical officers of the United States Public Health Service. "(ii) Medical officers of the United States Public Health Service shall be detailed for duty or employed at such ports of entry as the Secretary of Health and Human Services may designate, in consultation with the Attorney General. "(B) CIVIL SURGEONS.-- (i) Whenever medical officers of the United States Public -2- 09/10/97 WED 11:36 FAX 202 456 5581 DOMESTIC POLICY COL 007 Health Service are not available to perform examinations under this subsection, the Attorney General, in consultation with the Secretary of Health and Human Services, shall designate civil surgeons to perform the examinations. "(ii) Each civil surgeon so designated shall-- "(I) Have at least 4 years of professional experience unless the Secretary of Health and Human Services determines that special or extenuating circumstances justify the designation of an individual having a less professional experience; and "(II) Satisfy such other eligibility requirements as the Secretary of Health and Human Services may prescribe. "(C) PANEL PHYSICIANS.-- In the case of examinations abroad under this subsection, the medical examiner shall be a panel physician designated by the Secretary of State, in consultation with the Secretary of Health and Human Services. "(4) CERTIFICATION OF MEDICAL FINDINGS.-- The medical examiners shall certify for immigration officers, immigration judges, or consular officers, as the case may be, any communicable disease of public health significance or physical or mental disorder or behavior described in section 212(a)(1)(A) of this Act. "(5) VACCINATION ASSESSMENT.-- (A) The assessment referred to in subparagraph (2)(A)(ii) of this subsection is an assessment of the alien's record of vaccination against vaccine-preventable diseases including mumps, measles, rubella, polio, tetanus, diphtheria toxoids, pertussis, haemophilus-influenzae type b, and hepatitis B, as well as any vaccination against other diseases specified as vaccine-preventable by the Advisory Committee on Immunization Practices. -3- 09/10/97 WED 11:37 FAX 202 456 5581 DOMESTIC POLICY COL 008 "(B) Medical examiners shall inform aliens of the importance of immunizations and shall create an immunization record for the alien at the time of examination. "(C)(i) Adjustment of status applicants.-- Each alien applying for adjustment of status shall submit to the civil surgeon any available documents relating to the vaccinations described in subparagraph (5)(A) of this subsection. If the alien has not received the entire series of vaccines, the civil surgeon shall document on the vaccination record what steps, if any, the alien has taken to obtain the vaccines for the preventable diseases described in subparagraph (5)(A) of this subsection. "(ii) Immigrant visa applicants.-- Each alien applying for an immigrant visa shall submit to the panel physician any available documents relating to the vaccinations described in subparagraph (5)(A) of this subsection. If the alien has not received the entire series of vaccines, the panel physician shall document on the vaccination record what steps, if any. the alien has taken steps to obtain the vaccines for the preventable diseases described in subparagraph (5)(A) of this subsection. "(6) APPEAL OF MEDICAL EXAMINATION FINDINGS.- Any alien found by a medical examiner described in subparagraph (b)(3) of this subsection to have a medical condition that is a ground of inadmissibility under 212(a)(1)(A) of this Act may appeal that determination to a board of medical officers of the Public Health Service, which shall be convened by the Secretary of Health and Human Services. The alien may introduce at least one expert medical witness before the board at his or her own cost and expense. "(7) FUNDING.- (A)(i) The Attorney General shall impose a fee upon any person applying for adjustment of status to that of an alien lawfully admitted for permanent residence -4- WED 11:37 FAX 202 456 5581 DOMESTIC POLICY COL 009 under section 209, 210, 245, or 24SA of this Act, and the Secretary of State shall impose a fee on any person applying for a visa at a U.S. consulate abroad who is required to have a medical examination under paragraph (1) of this subsection. "(ii) The amounts of the fees required by subparagraph (7)(A)(i) of this subsection shall be established by the Secretary of Health and Human Services, after obtaining the concurrence of the Attorney General or the Secretary of State, as the case may be, and shall be set at such amounts as may be necessary to recover the full costs of establishing and administering the civil surgeon and panel physician programs, including the costs to the Immigration and Naturalization Service, the Department of State, and the Department of Health and Human Services for any additional expenditures associated with the administration of the fees collected. "(B)(i) The fees imposed under subparagraph (7)(A)(i) of this subsection may be collected as separate fees or as surcharges to any other fees that may be collected in connection with an application for adjustment of status under section 209, 210, 245, or 245A of this Act, for a visa, or for a waiver of inadmissibility under paragraph (1) or (2) of section 212(g) of this Act, as the case may be. "(ii) The provisions of the Act of August 18, 1856 (Revised Statutes 1726-28. 22 U.S.C. 4212-14), concerning accounting for consular fees, shall not apply to fees collected by the Secretary of State under this section. "(C)(i) There is established on the books of the Treasury of the United States a separate account on behalf of the Secretary of Health and Human Services which shall be known as the 'Medical Examinations Fee Account.' "(ii) There shall be deposited as offsetting receipts into the Medical Examinations Fee -5- 09/10/97 WED 11:37 FAX 202 456 5581 DOMESTIC POLICY COL 010 Account all fees collected under subparagraph (7)(A) of this subsection, to remain available until expended. "(iii) Amounts in the Medical Examinations Fee Account shall be available only to reimburse any appropriation currently available for the programs established by this section." -6- 09/10/97 WED 11:37 FAX 202 456 5581 DOMESTIC POLICY COL 011 08/25/97 13:32 202 842 9220 HQIRT 011 U.S. Department Justice Office of Legislative Affairs Office of the Assistant Attorney General Hashington. ac 20530 April 16, 1996 Honorable Robert Dole Majority Leader United States Senate Washington, D.C. 20510 Dear Senator Dole: This letter presents the views of the Administration concerning S. 1564, the "Immigration Control and Financial Responsibility Act of 1996", as reported by the Committee on the Judiciary on March 21, 1996. Many of the provisions in S. 1564 advance the Administration's four-part strategy to control illegal immigration. This strategy calls for regaining control of our borders; protecting U.S. workers and removing the job magnet through worksite enforcement; aggressively removing criminal and other deportable aliens; and securing from Congress the resources to support the Administration's illegal immigration enforcement strategy and to assist states with the costs of illegal immigration. Many of the provisions of S. 1664 are identical cr similar to provisions in the Administration's bill, S. 754, the "Immigration Enforcement Improvements Act ci 1995. While the Administration strongly supports reform of the current immigration law that deters illegal immigration, and S. 1564 contains many provisions that are similar or identical =0 the Administration's legislative proposal, enforcement initiatives, and overall strategy, 5. 1664 raises serious concerns in specific areas that we hope the Senate will examine thoroughly during floor consideration of the bill. The Administration's concerns include, but are not limited to the following: If S. 1664 were presenced to the President with provisions that would jeopardize any child's right to full participation in public elementary and secondary education, including pre-school and school lunch programs, the Secretary of Education and the Attorney General would recommend that the bill be vetoed. The Administration opposes broadening the application ci deeming rules from a well-defined set of programs to all means- tested programs including Medicaid, the Maternal and Child Health Services program, the School Lunch program. student financial assistance programs for postsecondary education and scores :: 09/10/97 WED 11:38 FAX 202 456 5581 DOMESTIC POLICY COL 08/25/97 1012 13:33 202 842 9220 HQIRT 012 they must submit a feasibility report to the House and Senate Committees on the Judiciary, and the House and Senate Committees on Armed Service: The use of closed military bases would make additional detention space available to INS. For years, INS has been forced to release many aliens who are awaiting proceedings due to lack of detention space. We have worked with the Department of Defense in conjunction with the Bureau of Prisons and other agencies to explore the use of closed bases. Conversion costs and staffing have been the most difficult problems to resolve. Accordingly. this provision does not address the underlying obstacles that would permit such a pilot to be conducted. Sec. 154 would amend section 212 of the INA to exclude aliens seeking permanent residency who have not received immunizations against vaccine-preventable diseases. While reducing the number of unvaccinated persons in the United States is a laudable goal, the mechanism outlined in this section would present a number of implementation and other difficulties that may actually jeopardize the public health in the United States. In many countries, the vaccines specified under this section might not be licensed. Even if these vaccines are licensed, they may not be readily available or the costs of these vaccines may be prohibitive for some prospective immigrants. In addition, an immigrant's visa could be delayed as much as 18 months in order to allow time to receive all recommended doses of the specified vaccines, over the interval recommended by the Advisory Committee Immunization Practices (ACIP) The ACIP- recommended vaccine schedule is complex and lengthy and subject to regular revisions. It would be difficult and labor intensive for Department of State and INS officials to check individual immunizations records against ACIP schedule and to ensure that U.S. government officials are using the most up- to-date revisions. Neither the Department of State nor the INS have the resources to verify the authenticity of most vaccination certificates. The requirements outlined in section 154 could subject immigrants to serious delays. considerable expense, and the prospect OÉ having to choose between emigrating as a family or splitting up the family to allow, for example, an adult CO emigrate to begin employment in the United States while other family members stay behind to complete the immunization requirements. The result might be that the immigrant will choose :: secure Salse immunization records rather than attempt to comply with the requirements imposed by section 154. If that were == happen, the immigrant. once admitted to the U.S., would 23 /6/0I/60 WED 11:38 FAX 202 456 5581 DOMESTIC POLICY COL 013 08/25/97 13:34 202 842 9220 HQIRT 013 be thought to have been vaccinated. Yet, the immigrant could become infected and could transmit a vaccine-preventable disease - to others in the U.S. To further confound the matter, the unimmunized person may be unwilling to admit he was not vaccinated, fearing that he could become subject to deportation. We also note that because of the lack of centralized immunization records in most countries, it would be difficult, if not impossible, for the INS and the State Department officials to detect fraudulent vaccination certificates. Under current state laws, children in the U.S. are required to comply with immunization requirements before they enter school. Therefore, the current public health system would "capture" school-aged immigrant children almost immediately upon entry into the U.S. Even without the proposed provision in the immigration bill, these children would be vaccinated once they came to the U.S. In addition, in many states, licensed day care establishments also have immunization requirements. We suggest modifying this provision and making immunization part of the medical examination process now covered by section see- 234 134 of the INA. In working with Senate staff, we understand that an amendment may be offered on the Senate floor that addresses our concerns regarding this section, which we support. Sec. 155 requires immigrants and nonimmigrants, except physicians, who seek CO work in the U.S. to obtain a qualifications certificate from the Commission on Graduates of Foreign Nursing Schools (CGFNS) or from an equivalent independent credentialing organization approved by the Attorney General in consultation with the Secretary of Health and Human Services. Such certificate must verify that (1) the individual's education, training, license, and experience meet statutory and regulatory requirements for admission to the U.S. under the classification specified, are comparable to that required for U.S. workers in the health care occupation. and any foreign license submitted is authentic and unencumbered; (2. the individual has English language proficiency as shown =y passing a nationally recognized standardized test of speaking and writing ability; and (3) if a majority of states licensing the profession recognize a test predicting success on the profession's licensing and certification examination, the alien has passed such a test. The imposition of the credentialing requirement may not be in conformity with certain U.S. international obligations. We recommend that the Senate adopt an amendment that would permit the Administration to address these concerns. Sec. 156 increases the bar = reentry for aliens previously removed under an exclusion order from one year to five years and to twenty years for any second == subsequent removal. This section also makes technical changes to section 275 of the INA. 19 09/10/97 WED 11:39 FAX 202 456 5581 DOMESTIC POLICY COL 014 08/25/97 13:35 HQIRT 014 202 842 9220 May 6, 1996 CONGRESSIONAL RECORD-SENATE S4743 SEC. 152. PILOT PROGRAM ON INTERIOR REPA. training in the diagnosis of Insanity and mental "(2)(A) The sees imposed under paragraph (1) TRLATION AND OTHER METHODS TO defects shall be detailed for duty or employed at may be collected as separate fees or as SUT- DETER MULTIPLE UNLAWFUL EN. such ports of entry as the Secretary may der- charges to any other sees that may be collected TRIES. igrate, in consultation with the Attorney Gen- in connection with an application for adjust- (a) ESTABLISMMENT-Not later than 180 days eval. ment of status under section 209. 210. 245. or after the date of the enactment of this ACL. the "(2) CIVIL SURGEONS-(A) Whenever medical 245A. for a visa, or for a waiver of excludability Attorney General. after consultation with the officers of the United States Public Health Serv- under paragraph (1) or (2) of section 212(g), as Secretary of State, shall establish a pilot pro- ice are not available to perform examinations the case may DE. gram for up to two years which provides for under this section, the Attorney General. in ''(B) The provisions of the ACL of August 18, methods to deter multiple unlawful entries by consultation with the Secretary. shall designate 1856 (Revised Statutes 1726-28, 22 U.S.C. 4212- aliens into the United States. The pilot program dull surgeons to perform the examinations. 14). concerning accounting for consular fees, may include the development and use of interior "(8) Each civil surgeon designated under sub- shall not apply to sees collected by the Secretary repatriation. third country repatriation. and paragraph (A) shall- of State under this section. other disincentives for mulliple unlaw/ul entries "(i) have at least 1 years of professional espe- "(I)(d) There is established or the books of into the United States. rience unless the Secretary determines that spe- the Treasury of the United States a separate ac- (b) REPORT.-Not later than 35 months after cial or extenuating circumstances justify the count which shall be known as the Medical EI- the date of the enactment of this Act, the Attor- designation of an individual having a lesser aminations Fee Account. ney General. together with the Secretary of amount of professional experience: and "(B) There shall be deposited as offsetting re- State. shall submit a report to the Committees on "(ii) satisfy such other eligibility requirements cripts into the Medical Examinations Fee Ac- the Judiciary of the House of Representatives as the Secretary may prescribe. and of the Senate on the operation of the pilot "(3) PANEL PHYSICIANS.-11 the case of exami- count all fees collected under paragraph (1), to nations under this section abroad. the medical remain available until expended. program under this section and whether the pilot-program or any part thereof should be eI- examiner shall de a panel physician designated "(C) Amounts in the Medical Examinations by the Secretary of State, in consultation with Fee Account shall be available only to reimburse tended or made permanent. the Secretary. any appropriation currently available for the SEC. 153- PROT PROGRAM ON USE OF CLOSED MILITARY BASES FOR THE DETEN. "(d) CERTIFICATION OF MEDICAL FINDINGS.- programs established by this section. TION OF EXCLUDABLE OR DEPORT. The medical examiners shall certify for the in- "(h) DEFINITIONS.-As used in this section- formation of immigration officers and special in- "(1) the term medical examiner refers to a ABLE ALIENS. guiry officers. or consular officers, as the case medical officer. civil surgeon. OF panel physi- (a) ESTABLISMMENT-The Attorney General may be, any physical or mental defect or disease cian, as described in subsection (c): and and the Secretary of Defense shall jointly estab- lish.a pilet program for up to two years to deter- observed by ruch examiners in any such alien. (a) the term 'Secretary' means the Secretary "(E) VACCINATION ASSESSMENT:-(I) The at of Health and Human Services. mine the feasibility of the use of military bases available through the defense base realignment sessment referred to in subsection (b)(1)(B) 4 an SEC 155. CERTIFICATION REQUIREMENTS FOR assessment of the alien's record of required DOC- FOREIGN HEALTHCARE WORKERS. and closure process as detention centers for the Immigration and Naturalization Service. cines for preventable diseases, including mumps, (a) IN GENERAL-Section 212(a) (8 U.S.C. measles. rubella, Dolio. telanus, diphtheria Lor- 1182(a)) 4 amended (b) REPORT-Nes later than 35 months after the date of the enactment of this ACL. the Attor- olds. perfussis. honophilus-influensa type B, (1) redesignating paragraph (9) as para- ney General, together with the Secretary of hepatitis type B. as well as any other diseases graph (10): and State. shall submit a report to the Committees on specified as vaccine-preventable by the Advisory (2) by inserting after paragraph (8) the follow Committee on Immunization Practices. ing new paragraph the Judiciary of the House of Representatives "(2) Medical examiners shall educate aliens "(9) UNCERTIFIED FOREIGN HEALTH-CARE and of the Senate. the Committee on National on the importance of immunizations and shall WORKERS.-(A) Any alien who seeks to enter the Security of the House of Representatives. and create on immunization record for the olien at United States for the purpose of performing. the Committee on Armed Services of the Senate. the time of examination. labor as a health-care worker. other than a on the feasibility of using military bases closed "(3)(A) Each alien who has not been pac- physician. is exclusiable unless the alten pre- through the defense base realianment and clo- cinated against measles. and each alien under sents to the consular officer RI. in of case of sure process as defension centers by the Immi- the age of 5 years who has not been vaccinated assustment of status, the-Attorney General, gration and Naturalization Service. against Dolio. must receive such vaccination, a certificate from the Commission OR Graduates SEC 154, PHYSICAL AND MENTAL EXAMINATIONS unless walved by the Secretary. and must TE- of Foreign Nursing Schools, or e certificate from Section 237 1 U.S.C. 1226) is amended to read ceive any other seccination determined Rec- an-equivalent idependeni credentialing organi- as follows: essary by the Secretary prior to arrival in the zation-approved by the Attorney General in con- "PHYSICAL AND MENTAL EXAMINATIONS United States. miliation with the Secretary of Health and "SEC. 234. (a) ALIENS COVERED.-Each alien '(B) Aliens who have not received the entire Human Services. verifyingthat= within any of the following classes of aliens series of vaccinations prescribed in paragraph "71) the alien's education. training. license. who is seeking entry into the United States shall (1) (other than measles) shall return to 4 des- and experience- undergo a physical and mental examination in ignated civil surgeon within 30 days of arrival "() meet all applicable statutory and regu- accordance with this section: in the United States, or within 30 days of ad- latory requirements for entry into the United "(1) Allens applying for visas for admission to justment of status, for the remainder of the vac- States under the classification specified in the the United States for permanent residence. cinations. application; "(2) Aliens seeking admission to the United "(f) APPEAL OF MEDICAL EXAMINATION FIND "(II) are comparable with that required for an States SOT permanent residence for whom exami- INCS.-Any alten determined to have a health- American health-care worker of the same type: nations LETE not made under paragraph (1). related grounds of exclusion under paragraph and "(3) Aliens within the United States seeking (1) of section 212(a) may appeal that determina- "(III) are authentic and, in the Case of a li- adjustment of status under section 245 to that of tion to a board of medical officers of the Public cense, unencumbered; aliens lawfully admitted to the United States for Health Service, which shall be convened by the "(ii) the alien has the level of competence in permanent residence. Secretary. The allen may introduce at least one oral and written English considered by the Sec- "(() Alien creamen entering or in transit arpert medical witness Defore the board at his or retary of Health and Human Services, in con- across the United States. her own cost and expense. sullation with the Secretary of Education, to be "(b) DESCRIPTION OF EXAMINATION-(1) Each "(g) FUNDING.-(1)(A) The Allorney General appropriate for health care work of the kind in examination required by.rubsection (a) shall in- shall impore a fee upon any person applying for which the atien will be engaged, as shown by an clude- adjustment of status to that of an alien lawfully appropriate score on one OF more nationally rec- "(A) an examination of the allen for any admitted to permanent residence under section ognized. commercially available, standardized physical or mental defect or disease and a CET- 209. 210. 245. of 245A. and the Secretary of State assessments of the applicant's ability to speak tification of medical Andings made in accord- shall impose a see upon any person applying for and write; and once with subsection (d): and a visa at a United States consulate abroad who "(lil) V a majority of States licensing the pro- "(B) on assessment of the vaccination record is required to have a medical examination in ac- Jession in which the alien intends to work recog- of the alien in accordance with subsection (c). cordance with subsection (a). nize a test predicting the success on the profes- "(2) The Secretary of Health and Human "(8) The amounts of the fees required by rub- sion's licensing and certification examination. Services shall prescribe nich regulations as may paragraph (A) shall be established by the See- the alien has passed ruch a test. be necessary to carry out the medical examina- relary, in consultation with the Attorney Gen- "(B) For purposes of subperagraph (A)(iD, de- lions required by subsection (a). eral and the Secretary of State. dr the case may termination of the standardized tests required TO MEDICAL EXAMINERS- be. and shall be set at such amounts as may be and of the minimum scores that are appropriate "()) MEDICAL OFFICERS.-(A) Except as pro- necessary to recover the full costs of establishing are within the sole discretion of the Secretary of vided in paragraphs (2) and (1). esaminations and administering the civil surgeon and panel Health and Human Services and are not subject under this section shall be conducted by medical physician programs, including the costs to the to further administrative or judicial review.". officers of the United States Public Health Serv- Service, the Department of State. and the De- (b) CONFORMING AMENDMENTS.- ices. partment of Health and Human Services for any (1) Section 101(f)(3) is amended by striking "(8) Medical officers of the United States additional expenditures associated with the ad- "(9)(A) of section 212(a)" and Inserting "(10)(A) Public Health Service who have had specialized ministration of the sees collected. of section 212(a)". 7-22-1997 4 1 1PM FROM P.2 DRAFT Administration Q: What is the Department doing in repsonse to the requirement in the 1996 Immigration law requiring immunizations for children being adopted DRAFT internationally? Administration A: The Department has been made aware of the concerns voiced in the international adoption community regarding the immunization requirements in the 1996 Immigration Law. The CDC is exploring this requirement from a public health perspective to ensure that technical guidance provided to the Immigration and Naturalization Service and the Department of State to assist in implementing this law does not interfere with the ability of doctors to exercise sound medical judgement regarding their patients. Background The 1996 amendments to the Immigration Act requires immunizations for the first time as part of the medical examination immigrants must pass before they are given a permanent resident visa. We provided technical and medical guidance to INS and DOS. INS decided that the new requirement would go into effect on July 1, 1997. The international adoption community believe that children adopted abroad and brought to the United States by American parents should be exempt from the new requirement. They argue that vaccines and vaccine practice may not be safe in some foreign countries and that the scanty medical records of foreign orphans are generally insufficient to allow determination of whether a medical contraindication might exist. INS believes they do not have authority to grant a blanket waiver to adoptees. The Department is receiving many calls from the Hill and others on this issue. We are working with INS, DOS, and the Hill to determine, what, if anything can be done to assuage the concerns for the international adoption community. DRAFT 7-22-1997 4: 1 PM FROM P.2 DRAFT Administration Q: What is the Department doing in repsonse to the requirement in the 1996 Immigration law requiring immunizations for children being adopted DRAFT internationally? Administration A: The Department has been made aware of the concerns voiced in the international adoption community regarding the immunization requirements in the 1996 Immigration Law. The CDC is exploring this requirement from a public health perspective to ensure that technical guidance provided to the Immigration and Naturalization Service and the Department of State to assist in implementing this law does not interfere with the ability of doctors to exercise sound medical judgement regarding their patients. Background The 1996 amendments to the Immigration Act requires immunizations for the first time as part of the medical examination immigrants must pass before they are given a permanent resident visa. We provided technical and medical guidance to INS and DOS. INS decided that the new requirement would go into effect on July 1, 1997. The international adoption community believe that children adopted abroad and brought to the United States by American parents should be exempt from the new requirement. They argue that vaccines and vaccine practice may not be safe in some foreign countries and that the scanty medical records of foreign orphans are generally insufficient to allow determination of whether a medical contraindication might exist. INS believes they do not have authority to grant a blanket waiver to adoptees. The Department is receiving many calls from the Hill and others on this issue. We are working with INS, DOS, and the Hill to determine, what, if anything can be done to assuage the concerns for the international adoption community. DRAFT Leanne A. Shimabukuro 07/11/97 08:20:20 PM Record Type: Record To: Jennifer L. Klein/OPD/EOP CC: Jose Cerda III/OPD/EOP, Nicole R. Rabner/WHO/EOP Subject: Immunization and immigration I'm sorry that you had to miss the meeting today-- I hope everything is ok with the baby. The meeting went pretty well: we had representatives from State, INS, HHS, and CDC. In a nutshell, there is general consensus that we do not think we have the ability to waive the new immunization requirement in the immigration law for adopted children. Moreover, equity issues over the immunization requirement were raised with respect to children coming in on other, non-adoption visas. For instance, if vaccinations are unsafe for adopted children abroad, they are probably unsafe for all immigrant children coming from that country, and possibly adults as well. The State Department said that they have been doing outreach to their consular offices on this specific issue and have not heard that implementation of the new requirement is turning into a big problem. They are sending/posting on the Internet some really useful questions and answers aimed at parents adopting children, which should clear up some of the confusion. I have red-dotted a copy of this to you. I have also tasked HHS (Traci Endo, Irene Bueno) to help coordinate our positions on the 7 key concerns that the adoptions community keep raising. Different agencies have been responding to different pieces of the puzzle and I thought it would be useful to pull it all together in one document. I think they should have something next week. I told the participants at the meeting that the WH was expecting to have an immunization event soon. I heard this afternoon from Christa that it is scheduled for the 23rd. HHS (Traci Endo) will be coordinating with some of the other agencies to get some Q&A to you on this issue which could be raised in the context of the event. The people who will be expecting your call are: Traci Endo at HHS: 690-6786 Bob Hannan at State: 663-1251 You should also give Steve Warnath a call. Sorry this is so long Leanne sen- from State Dept 7147 LMS is a state Dept document. Thanks, Learne 212(a)(1)(A)(ii) Vaccination Requirement and Adoptions Adoptive parents and adoption agencies have raised concerns about the impact of the immigrant vaccination requirement on adopted children. These concerns, and our responses, are outlined below for your reference and use in responding to inquiries. Can't you waive this requirement for my adopted child? Consular officers do not have the authority to exempt adopted children from the requirement. The legal authority for granting and denying waivers rests with the Immigration and Naturalization Service INS. The law does authorize waivers in situations where the panel physician determines that it would be medically inappropriate for an applicant to receive a specific vaccine, whether due to the applicant's age or medical history/condition, or the local unavailability of the vaccine. INS has delegated authority to Consular officers to grant blanket waivers in these cases. This means that the waiver can be granted without the need for the applicant to file an application form or to pay a fee. Can I get a waiver if I have moral or religious objections to my child receiving vaccinations? Persons who have religious or moral objections to receiving vaccinations can apply for an individual waiver from the INS. Individual waivers are adjudicated by INS on a case-by- case basis, and can take significant time to process. We' re afraid our child will be vaccinated using unsterilized needles. Reports concerning the use of unsterilized needles involve vaccinations administered to children in orphanages, either as a result of the institution's policy or local government law. We have no reason to believe that the U.S. vaccination requirement will encourage these institutions to administer vaccinations if they do not already do so. Panel physicians, who administer the vaccinations in accordance with the Center for Disease Control (CDC) guidelines, use sterilized needles and syringes. Parents who are considering taking their own syringes and needles to the medical exam should be warned that they could face problems entering a foreign country with what might appear to be drug paraphernalia. Who are panel physicians? Panel physicians are local practitioners who have been selected by the Embassy or Consulate to conduct immigrant medical exams in accordance with CDC guidelines, and whose performance is monitored to ensure compliance with these guidelines. In many countries, the Embassy or Consulate's staff rely on the same physicians for their own medical care. Consular officers have been working closely with their panel physicians to ensure that they understand the CDC guidelines and have identified potential problems. We are confident that panel physicians will follow basic safe medical practices in administering the vaccines, starting with the use of sterilized needles. Should we learn that a panel physician is not practicing safe procedures, we would take immediate action to remedy the situation. I know that a child who is immunocompromised should not receive the required vaccinations. It takes extensive and highly sophisticated tests, however, to determine that a child is immunocompromised. I am afraid that my child will experience a major adverse reaction to a vaccination on the flight home. Such medical issues should be referred to the CDC, which is responsible for promulgating the technical instructions which panel physicians follow in implementing the vaccination requirement. I don't want to fly back to the U.S. with a child who has just received a battery of vaccinations. We strongly encourage adoptive parents to take their child(ren) into the panel physician for the medical exam and vaccination assessment as early as possible. This should ensure that children have adequately recuperated from any minor reactions to the vaccinations by the time they travel. (ATTACHED) 6/6/97 from William Pierce, Pres., National Council For Adoption, requesting your assistance regarding regulations for vaccinating children coming to the U.S., scheduled to take effect July 1. He encloses L.A. Times story which nicely summarizes the issue. To Melanne + Nicole r Jen for review/response pultre Melanne Verveer Nicale -ony word on this ? 1 06/06/1997 14:01 2023320935 NCFA PAGE 01 MM National Council For Adoption "Help Build Happy Families" DETERMINED TO BE AN PERSONAL AND CONFIDENTIAL ADMINISTRATIVE MARKING June 6, 1997 INITIALS: a DATE: 10/17/12 The First Lady The White House By fax 456-6244 Dear Mrs. Clinton: At our recent event, I had the opportunity to thank you publicly for your work on adoption. Again, many thanks. I can also report to you that one of our staff was at an HHS briefing this morning and it appears that the MEPA regulations are on target. I am also writing about a unique opportunity for you to get involved on behalf of adoption. In brief, last year's changes in the immigration law require vaccinations for all children coming to the U.S. Except for children who are to be adopted, this may be sound policy. To my knowledge, the entire adoption community and that part of the medical community which specializes in pediatrics and international medical issues agrees that it would be a health error of major proportions to allow the regulation implementing this requirement to take effect July 1. You can help avert this crisis. Many groups and people have been working on this, each in their own way. I've been trying to find some simple, non-confrontive administrative solution but although people at State and elsewhere have been very understanding, the law does not provide enough flexibility to deal with the problem. The issue is nicely summarized in a Los Angeles Times story by Marlene Cimons, a copy of which (from the internet) is provided for you with this letter. At this stage, it seems to me what would work would be for you to get personally involved and present the case to the President, seeking an Executive Order keeping the regulation from going into effect. It would be wonderful to have you and the President make the announcement as soon as possible, or in a Saturday radio address before July 1; for instance. The practical effects? Imagine taking a child who's just had 11 shots on a 14-hour plane ride. Or waiting five extra days in Moscow, while your child gets these shots that make her sick, paying an extra $200 a day. We're talking about 2,500 children, 200 a month. Sincerely William Brown Pierce, President Enclosure: as stated 1930 Seventeenth Street, N.W. Washington, D.C. 20009-6207 202-328-1200 FAX 202-332-0935 06/06/1997 14:01 2023320935 NCFA PAGE 02 From: "Brenda McParland" <[email protected]> To: [email protected] Critics Finding Holes in Overseas Vaccination Law By MARLENE CIMONS, Times Staff Writer WASHINGTON--A first glance, the regulation seems beyond debate. As part of the immigration law passed last year, all individuals seeking permanent entry into this country must prove that they have been inoculated against all vaccine-preventable diseases. But health experts, especially those who specialize in medical issues for children adopted from abroad. are alarmed that the rule will do more harm than good to the thousands of foreign-born youngsters who arrive here for adoption. Among other things the experts are worried about the quality of the vaccines available, as well as the possibility that substandard medical practices will contribute to the transmission of dangerous diseases as vaccines are administered. "Sometimes, things that seem like good ideas really aren't," said Dr. Dana Johnson, director of the University of Minnesota's division of neonatology. "Apparently no one thought through all the ramifications." The requirement, which goes into effect July 1, "potentially endangers vulnerable children," said Dr. Laurie C. Miller, director of the International Adoption Clinic at New England Medical Center in Boston. "The risk is very real in most countries from which international adoptees come." ... Johnson said he would prefer that the State Department assume responsibility for overseas vaccination programs rather than trusting local physicians to do the job, but this is considered unlikely. An alternative touted by some health experts is to waive the requirement for infants and children and allow adoptive families to have the shots administered by their own pediatricians when children arrive--which already occurs in most instances, he said. Last year, 11,316 children were adopted from overseas, the Immigration and Naturalization Service says. The numbers of sudh adoptions have been on the upswing in recent years. As it has become more difficult to adopt U.S.-born babies, Americans have turned to other countries, among them Russia, Romania, India. China and Latin 06/06/1997 14:01 2023320935 NCFA PAGE 03 American nations. Many of these children live in poverty, or have been in orphanages where medical care is scarce or nonexistent. Often there is little or no medical history available on the youngsters, according to the Joint Council on International Children's Services, a coalition of international adoption agencies. A chief fear among health experts is that the required injections will be administered with unsterile needles--a frequent practice outside the United States because of a shortage of disposable needles and syringes. This can transmit such potentially deadly blood-borne infections as Hepatitis B and C and HIV. Diseases like Hepatitis B, rare in U.S.-born children, are endemic to Asia and Eastern Europe. Furthermore, many countries cannot afford high-quality vaccines more readily available here. Instead, they use biologically impotent products, those that have expired or have not been properly refrigerated or stored. The experts also are worried that foreign orphanages may not be equipped to deal with medical emergencies that could result from vaccinations. Some children, for example, are allergic to certain vaccines. And some vaccines, such as polio, are made from live but weakened virus and actually can cause the disease in a small number of children. Rep. Bill McCollum (R-Fla), House sponsor of the vaccination provision, expressed surprise at the concerns being raised. He said: "It certainly wasn't meant to put anyone's health at risk. If that's the case, then maybe we ought to explore It and, if necessary, correct it." But a spokesman for Sen. Jon Kyl (R-Ariz.), who sponsored the provision in the Senate, said the law provides for waivers to the requirement in certain circumstances. These include religious objections or cases where the injections are deemed "medically inappropriate." The latter includes situations in which a child is too young to be vaccinated or in which an individual is known to be allergic to a vaccine. However, the waiver provisions do not appear to apply to questionable vaccine standards or sterilization practices. Copyright Los Angeles Times 06/23/1997 17:53 2023320935 NCFA PAGE 01 Jerri Ann Jenista, MD 551 Second Street Ann Arbor, MI 48103 USA 313-668-0419 313-668-9492 (fax) May 27, 1997 Ms. Mary Ryan Deputy Assistant Secretary of State for Consular Affairs US Department of State 2430 E Street NW Washington, DC. 20037-2800 Dear Secretary Ryan, I am writing to express concern about the new requirements for immunization of permanent resident allens, scheduled to go Into effect on July 1, 1997. These rules are inappropriate for the processing of visas for children adopted abroad by US citizens. As an adoptive parent, pediatrician specializing in Infectious diseases and long-time researcher on the health of children adopted from abroad. I find significant areas of concern in these new requirements. The safety of children may be compromised. Most immigrant children are traveling with family members or adults who know their past medical history. Even unaccompanied refugee children have spent some time in B processing center under medical observation. Different from these other immigrant or refugee children. adopted children are accompanied by perents who have had only a few days contact with the children and, for the most part. are unaware of the child's past medical history. Even when the child has been under appropriate medical supervision; the records typically do not accompany the child or are in a language the parents cannot read. Adoptive parents may be unaware of any history of allergies or adverse reactions to past immunizations. Distressing and possibly even life-threatening reactions to vaccines would be very difficult to manage while staying in a hotel in a foreign country without access to familier medical care. Most families travel immediately after the visa is issued and thus might have to deal with these serious problems while on a long intercontinental flight. Children may be immunocompromised by any number of hidden problems such as: HIV infection undisgnosed tuberculosis chronic stress due to social problems and/or institutional living mainutrition other chronic disease Good Immunization practice requires a careful assessment of the child's health and immunologic status. This type of evaluation is neither appropriate nor possible in the cypical visa medical evaluation. Numerous studies have shown that the majority of adopted immigrant children have significant health concerns which are not discovered until after errival in the US. Giving immunizations hastily to these children is not only a waste of vaccine resources but also may risk Infection from live vaccines such as polic, measles or varicella. Nicole RAdnor F:456-2878 P. of 3 06/23/1997 17:53 2023320935 NCFA PAGE 02 There are significant concerns about the vaccine administration process itself. Children coming from orphanages and other Institutions typically have the least access to good medical care. Even if vaccines and clean needles and syringes are available in the country, the adopted child may have no access to those resources. Adoptive parents cannot be expected to transport vaccines which may have to be refrigerated 01 otherwise handled carefully. Adoption agencies and lawyers cannot ethically supply vaccines to an orphanage for the sole use of children to be adopted, ignoring the other children unavailable for adoption. Some countries prohibit the use of unapproved vaccines or administration of vaccines by anyone except special government clinics. Again, adopted children are unlikely to have access to these resources. The quality of vaccines is in question In some countries. There is no way to assess the quality of any vaccine given to an individual child. In some regions where refrigeration cannot be guaranteed, the child may be vaccinated with a defective and ineffective product. Adoptive parents are not allowed the opportunity to give a fully informed consent before the child is Immunized Many adoptive parents will not have parented a child before and will not know the pros and cons of each vaccine. Vaccine Information sheets, required in the US, are not likely to be available to adoptive perents Even If attempts are made to inform parents, the visa examination is the end of a long and stressful adoption journey and It is likely that parents will be unable to evaluate the information in a thoughtful manner. The costs of this program are potentially great. Because of the questions of quality and effectiveness of vaccines given in other countries under less than optimal circumstances and 1:0 children of unknown Immune status, most US physicians repeat the entire series. Thus, a child will have to receive many more doses of vaccines, increasing the cost and the potential for adverse resctions. In addition, it is unlikely that US health Insurance plans will cover the cast of vaccines administered overseas, Increasing the out-of-pocket costs in an already very expensive adoption process. The immunization process will cause unnecessary stress to children and parents. Typically, the visa medical examination is the lest step before the adoptive family is ready to travel to the US. Overwhelmed by the process of becoming a new family and the stress of travel in a foreign country, often under very physically difficult circumstances, the last thing a family needs is to have to subject their new son or daughter to a painful (and probably unnecessary) medical procedure. Unable to communicate to the child in his own language, parents will have to deal with a child whose first impressions of his new family will be colored by a painful experience. Immunizations given just prior to travel will not prevent cases of incubating infection such B9 messles or varicella. Thus, the Intent of the law, to prevent importation of Infectious diseases, will not be accomplished. Adoptive parents are an extraordinarily health conscious group. in my 20 years of experience in dealing with this special group of parents, I know that they are usually in the doctor's office within hours of arrival in the US and are the first to demend any preventive health measure for their precious new child. Thus, it is unlikely that they will fail to complete the required immunization series. 06/23/1997 17:53 2023320935 NCFA PAGE 03 Adoptive parents are US citizens and their children are US citizens by virtue of adoption. Unlike other immigrant children, adopted children do not have to undergo the legal. process of naturalization to gain citizenship. Like any child born to an American citizen abroad, the child merely makes an application for a certificate of citizenship. Thus, adopted immigrant children should be treated as US citizens, not as Immigrants, from the moment of adoption. They should receive the same consideration as any child born to an American parent, that is, immunization at the parent's discretion, with informed consent, following an appropriate medical evaluation To treat adopted children as other immigrants is depriving them of rights they gained by adoption into a US family. Increasing flexibility in the granting of waivers to the Immunizations will not resolve the above issues. It is very likely that the rules for waivers would be interpreted differently in different countries, thus subjecting perents to an uncertain process, depending on which physician Is providing the medical examination. The most appropriate solution to the question of immunization far adopted immigrant children is to provide a blanket waiver For all IR-3/IR-4 visas. By adding snother box to the list of reasons for a blanket walver, the examining physician need do nothing more than place a check and complete the usual process. This would allow for consistent processing worldwide for all adopted children, would eliminate the unnecessary risks to these new US citizens and would not prolong the visa process at the end of a long and stressful journey. Thank you very much for your consideration., Please feel free to contact me for additional Information. Sincerely, Jerri Ann Jenista, MD Editor, Adoption/Medical News Member, Committee on Early Childhood, Adoption and Dependent Care, American Academy of Pediatries cc: US Represenative Lynn Rivers Robert Wainwright MD, National Center for Infectious Diseases Neal Halsey, MD, American Academy of Pediatrics Red Book Committee US Senator Jon Kyl US Representative Bill McCollum US Senator Spencer Abraham 06/24/1997 10:48 2023320935 NCFA PAGE 01 TEL 301-588-3091 Jun 24.97 9:08 No. 002 P.01 Nicole Radnor- Cradle of Hope FYI Adoption Center, Inc. Bill TO: BILL PIERCE MAUREEN EVANS FR: LINDA PERILSTEIN RE: IMMUNIZATION REQUIREMENTS DT: 24 JUNE 87 Dear Maureen and Bill: I want to share with you the first immunization nightmare that's been reported to me out of Moscow. This incident allegedly occurred to non-Cradle of Hope families, 80 I cannot independently confirm it, but here goes: Several couples presented their chidren's immunization records to the US Embassy in Moscow, even though the requirement is not yet in effect. The children were lacking several immunizations, including Hep B. The Embassy told them to take the children to the American Medical Center in Moscow to obtain the missing shots. The American Medical Center said they wouldn't give the shots without authorization of the Russian Ministry of Health, which I don't understand because the children were already adopted and their new parents should be able to order any medical procedure they like. The Ministry of Health refused to authorize the shots, because the Hep B immunizations haven't been approved in Russia yet, and because of the concern of giving three different shots at one time. I'm not sure how or if this problem was resolved, but it illustrates the kinds of hassles we're in for. Linda Post-it Fax Note 7671 To Date 6-24 # of pages Nicole Radner / Co./Dept. From William Pierce Co. NCFA Phone # Phone # 202.328.1200 Fax # 202.456.2878 Fax # 202.332.0935 Main Office . 8630 Penton Street Sulte 310 Silver Spring MD 20910 301.587.4400 FAX 301.588.3091 D.C. Office 1815 H Bureet, N.W. Subte 600 Washington. D.O. 20008 202.288.4700 06/20/1997 14:22 2023320935 NCFA PAGE 02 Melanne Verveer MM National Council For Adoption Nicale - Do "Help Build Happy Families" we know anything more? ? June 20, 1997 The First Lady The White House Washington DC Dear Mrs. Clinton: I am writing once again about the vaccination requirements due to take effect July 1. It has been helpful talking with your staff, who have recommended - - as have others that we take the issue up with the Congressional Committees that were responsible for the change in the procedure. We've done that, but frankly the sense of urgency that is felt by the adoption community is not fully reflected on the Hill. I've been told July 1 may come and go, without a resolution - - and that perhaps INS has the power to do what's needed without additional tweaking of the Immigration and Nationality Act. Therefore, we've informally said that we would wait until the end of June 23 for INS or other non-legislative action to solve the problem, but if that deadline passes our word to the adoption field will be: press for a Congressional solution before July 1. We do expect that people will be petitioning The President and you for help, as the July 1 deadline approaches either to seek a response from INS or an Executive Order. That is why I wanted to give you an update. On the adoption subject, but closer to home, Carolyn Lamm told me at her reception June 17th that she was excited about your interest in helping improve the situation in D.C. I told Carolyn that NCFA would be glad to help in any way, including in an off-the-record and behind the scenes fashion. Do call on us if we can be of assistance. Thank you, as always, for your deep concern about adoption. Bill Pierce WP/ms hrc62097 1930 Seventeenth Street. N.W. Washington. D.C. 20009-6207 202-320-1200 FAX 202-332-0935 06/20/1997 14:22 2023320935 NCFA PAGE 03 MM National Council For Adoption Nicole Rodnos "Help Build Happy Families" FYF - June 20, 1997 The First Lady RM Pmin The White House Washington DC Dear Mrs. Clinton: I am writing once again about the vaccination requirements due to take effect July 1. It has been helpful talking with your staff. who have recommended - - as have others - that we take the issue up with the Congressional Committees that were responsible for the change in the procedure. We've done that, but frankly the sense of urgency that is felt by the adoption community is not fully reflected on the Hill. I've been told July 1 may come and go, without a resolution - and that perhaps INS has the power to do what's needed without additional tweaking of the Immigration and Nationality Act. Therefore, we've informally said that we would wait until the end of June 23 for INS or other non-legislative action to solve the problem, but if that deadline passes our word to the adoption field will be: press for a Congressional solution before July 1. We do expect that people will be petitioning The President and you for help, as the July 1 deadline approaches - - either to seek a response from INS or an Executive Order. That is why I wanted to give you an update. On the adoption subject, but closer to home, Carolyn Lamm told me at her reception June 17th that she was excited about your interest in helping improve the situation in D.C. I told Carolyn that NCFA would be glad to help in any way, including in an off-the-record and behind the scenes fashion. Do call on us if we can be of assistance. Thank you, as always, for your deep concern about adoption. Bill Pierce WP/ms hrc62097 1930 Seventeenth Street, N.W. Washington, D.C. 20009-6207 202-328-1200 FAX 202-332-0935 06/20/1997 14:22 2023320935 NCFA PAGE 04 AM National Council For Adoption "Help Build Happy Families" Melanue Verveu- FYI - - June 20, 1997 Bill Pien The First Lady The White House Washington DC Dear Mrs. Clinton: I am writing once again about the vaccination requirements due to take effect July 1. It has been helpful talking with your staff, who have recommended as have others - that we take the issue up with the Congressional Committees that were responsible for the change in the procedure. We've done that, but frankly the sense of urgency that is felt by the adoption community is not fully reflected on the Hill. I've been told July 1 may come and go, without a resolution - - and that perhaps INS has the power to do what's needed without additional tweaking of the Immigration and Nationality Act. Therefore, we've informally said that we would wait until the end of June 23 for INS or other non-legislative action to solve the problem, but if that deadline passes our word to the adoption field will be: press for a Congressional solution before July 1. We do expect that people will be petitioning The President and you for help, as the July 1 deadline approaches - either to seek a response from INS or an Executive Order. That is why I wanted to give you an update. On the adoption subject, but closer to home, Carolyn Lamm told me at her reception June 17th that she was excited about your interest in helping improve the situation in D.C. I told Carolyn that NCFA would be glad to help in any way, including in an off-the-record and behind the scenes fashion. Do call on us if we can be of assistance. Thank you, as always, for your deep concern about adoption. Bill Pierce WP/ms hrc62097 1930 Seventeenth Street, N.W. Washington, D.C. 20009-6207 202-328-1200 FAX 202-332-0935 Patrick Purtill 06/10/1997 09:25 2023320935 NCFA PAGE 02 MM National Council For Adoption "Help Build Happy Families" FAXE PERSONAL AND CONFIDENTIAL June 6, 1997 DETERMINED TO BE AN The First Lady ADMINISTRATIVE MARKING The White House By fax 456-6244 INITIALS: @ no DATE: 10/17/12 Dear Mrs. Clinton: At our recent event, I had the opportunity to thank you publicly for your work on adoption. Again, many thanks. I can also report to you that one of our staff was at an HHS briefing this morning and it appears that the MEPA regulations are on target. I am also writing about a unique opportunity for you to get involved on behalf of adoption. In brief, last year's changes in the immigration law require vaccinations for all children coming to the U.S. Except for children who are to be adopted, this may be sound policy. To my knowledge, the entire adoption community and that part of the medical community which specializes in pediatrics and international medical issues agrees that it would be a health error of major proportions to allow the regulation implementing this requirement to take effect July 1. You can help avert this crisis. Many groups and people have been working on this, each in their own way. I've been trying to find some simple, non-confrontive administrative solution but although people at State and elsewhere have been very understanding, the law does not provide enough flexibility to deal with the problem. The issue is nicely summarized in a Los Angeles Times story by Marlene Cimons, a copy of which (from the internet) is provided for you with this letter. At this stage, it seems to me what would work would be for you to get personally involved and present the case to the President, seeking an Executive Order keeping the regulation from going into effect. It would be wonderful to have you and the President make the announcement as soon as possible, or in a Saturday radio address before July 1, for instance. The practical effects? Imagine taking a child who's just had 11 shots on a 14-hour plane ride. Or waiting five extra days in Moscow, while your child gets these shots that make her sick, paying an extra $200 a day. We're talking about 2,500 children, 200 a month. William Brown Pierce, President Sincerely Enclosure: as stated 1930 Seventeenth Street, N.W. Washington, D.C. 20009-6207 202-328-1200 FAX 202-332-0935 06/10/1997 09:25 2023320935 NCFA PAGE 03 L.A. Times From: "Brenda McFarland" <[email protected]> To: [email protected] Critics Finding Holes in Overseas Vaccination Law By MARLENE CIMONS, Times Staff Writer WASHINGTON--A first glance, the regulation seems beyond debate. As part of the immigration law passed last year, all individuals seeking permanent entry into this country must prove that they have been inoculated against all vaccine-preventable diseases. But health experts, especially those who specialize in medical issues for children adopted from abroad. are alarmed that the rule will do more harm than good to the thousands of foreign-born youngsters who arrive here for adoption. Among other things, the experts are worried about the quality of the vaccines available, as well as the possibility that substandard medical practices will contribute to the transmission of dangerous diseases as vaccines are administered. "Sometimes, things that seem like good ideas really aren't," said Dr. Dana Johnson, director of the University of Minnesota's division of neonatology. "Apparently no one thought through all the ramifications." The requirement, which goes into effect July 1, "potentially endangers vulnerable children," said Dr. Laurie C. Miller, director of the International Adoption Clinic at New England Medical Center in Boston. "The risk is very real in most countries from which international adoptees come." Johnson said he would prefer that the State Department assume responsibility for overseas vaccination programs rather than trusting local physicians to do the job, but this is considered unlikely. An alternative touted by some health experts is to waive the requirement for infants and children and allow adoptive families to have the shots administered by their own pediatricians when children arrive--which already occurs in most instances, he said. Last year, 11,316 children were adopted from overseas, the Immigration and Naturalization Service says. The numbers of sudh adoptions have been on the upswing in recent years. As it has become more difficult to adopt U.S.-born babies, Americans have turned to other countries, among them Russia, Romania, India. China and Latin 06/10/1997 09:25 2023320935 NCFA PAGE 04 American nations. Many of these children live in poverty, or have been in orphanages where medical care is scarce or nonexistent. Often there is little or no medical history available on the youngsters, according to the Joint Council on International Children's Services, a coalition of international adoption agencies. A chief fear among health experts is that the required injections will be administered with unsterile needles--a frequent practice outside the United States because of a shortage of disposable needles and syringes. This can transmit such potentially deadly blood-borne infections as Hepatitis B and C and HIV. Diseases like Hepatitis B, rare in U.S.-bom children. are endemic to Asia and Eastern Europe. Furthermore, many countries cannot afford high-quality vaccines more readily available here. Instead, they use biologically impotent products, those that have expired or have not been properly refrigerated or stored. The experts also are worried that foreign orphanages may not be equipped to deal with medical emergencies that could result from vaccinations. Some children. for example, are allergic to certain vaccines. And some vaccines, such as polio. are made from live but weakened virus and actually can cause the disease in a small number of children. Rep. Bill McCollum (R-Fla), House sponsor of the vaccination provision, expressed surprise at the concerns being raised. He said: "It certainly wasn't meant to put anyone's health at risk. If that's the case, then maybe we ought to explore it and, if necessary, correct it." But a spokesman for Sen. Jon Kyl (R-Ariz.), who sponsored the provision in the Senate, said the law provides for waivers to the requirement in certain circumstances. These include religious objections or cases where the injections are deemed "medically inappropriate." The latter includes situations in which a child is too young to be vaccinated or in which an individual is known to be allergic to a vaccine. However, the waiver provisions do not appear to apply to questionable vaccine standards or sterilization practices. Copyright Los Angeles Times Chris / Woman Gany shaffer 663-1173 Bill Pievce: colleague 306 Hannon 663-1251/ International adoption coordinating ofc of Connector Affairs till tune25 = vacation tried to wk creatively of Center for Disease control to metigato Mary Bourdette problems - Congressional inquiries debating trill - House Foreign adop tim: no one taking leads interest: Pryce, Deborah (R) Authorizationll amendment. Kiel Senate Dewine no signal. July 1 : regulations go into effect. authorization. Dept. of State New requirement prohibits ewhy of alen dangerous decease of Foreign naturals covery pub wall sugmificant w/o a record of having new - come in as 1mm. If a physician deferunces that part immunir. - waived. we contract foreign physicians. busic childhood immir. - med. Ivive inapprop. - gets waived. CDC /AG - writes reg based on Reg. any exemption - statutory P.O. 514-2907 fao 514-1117 CDC Bob Steve Waventh NSC sudy Rogers INS Cong / CON INSIMP Michele Bernector, State Bub, Hannon State Sophia kotz, INS? Ed Odean Reg, Ron Acker 8/6/97 senate Can, just, State - 2 amend ments - nevded to enempt adoptive children from 1mmunize the Gregg put in an enfirement prece - (mhing waived wd be subject develop an enforment state Maureen, luter'l Contener Service, foint councel amendment desn't provide Legal ground for exemption for urphans, concerned about Wavier anth - use doesn't do any my if circle. Kyle (McCain - compromise anywage may 6 .96 pg 5-4743 R. Moove 410/252-7373 rm 316 I Bill Pierce age appropriate Naccinations * central data base for foster care hids CDRI - introenterpouse - child care scholarships- sup institutions. community schools ABC 6/23 vaccuation issue up to age 4 Q-11 mo 3 vacc /drops according to CDC