The California Department of Health (CDPH) is threatening to restrict funding for the more than 600 schools being audited by the state because they reported more than 10% of their kindergarten or seventh grade students were not fully vaccinated last year or because they failed to file a vaccination report with the state, EdSource reported.

“Schools found to have improperly admitted students who have (not) met immunization requirements may be subject to loss of average daily attendance payments for those children,” the CDPH said in an email.

CDPH posted the audit list, which included 449 schools with kindergarten students, 175 schools with seventh graders, 56 schools with both grades and 39 schools that had not filed a vaccination report.

California students are considered “not fully vaccinated” if they have not provided proper immunization records to their school, if they don’t have the vaccinations required by the school system or if they have been admitted to schools conditionally while they are in the process of finishing their school-mandated vaccine series, according to the state audit guide.

If a student behind on the vaccine requirements has not received a first dose of a required vaccine within 10 days of starting school and a second dose of a required vaccine within four months of the first dose, the student must be excluded from school.

The audit guide indicates that to determine whether schools have students behind schedule, auditors check whether kindergarteners have two doses of a varicella (chickenpox) vaccine and two doses of a measles vaccine and whether seventh graders have two doses of varicella and one dose of Tdap (tetanus, diphtheria and pertussis), their sixth pertussis-containing vaccine.

Oakland Unified School District, with 48 elementary schools and eight of the seventh grade schools on the list, has the highest number of schools being audited. Los Angeles Unified has 75 of its non-charter schools on the audit list, while Pomona Unified has 13, San Francisco Unified 14 and San Juan Unified in Sacramento County, eight.

The vaccination audit has been occurring in public schools only since the 2021-2022 school year, when 45 schools made the list.

Schools in violation of the state law must submit corrected attendance reports that reflect the reduction in average daily attendance cited in the audit finding, which will likely reduce their funding, according to CDPH spokesperson Scott Roark.

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Sensationalizing vaccine numbers

Over the last year, legacy media organizations such as The New York Times, CNN and The Washington Post along with public health officials across the country have been sounding the alarm over decreasing rates of routine vaccination among U.S. children.

But even at its lowest point — the 2020-2021 school year — the kindergarten vaccination rate only dipped to 94% from 95%, according to the Centers for Disease Control and Prevention (CDC).

Experts cited in these articles blame the drop on pandemic disruptions to U.S. healthcare, “vaccine hesitancy” about the COVID-19 vaccine bleeding over into other vaccines and the availability of non-medical vaccine exemptions.

EdSource reported that vaccination rates in California, which had been climbing since the state eliminated the personal belief exemption in 2015, plunged after schools closed during the COVID-19 pandemic.

Thousands of children in California were unable to start the school year in 2022 because they were behind on their vaccinations, it reported.

But EdSource also reported that the kindergarten vaccination rate was 92.8% in 2020 — down from 95% in 2018 — but went back up to 94% in 2021.

Substack writer and analyst Karl Kanthak told The Defender these numbers are being used to create the appearance of a crisis, which he says is part of a broader attack on vaccine exemptions.

Between the National Childhood Vaccine Injury Act of 1986, which gave vaccine makers immunity for any injuries caused by vaccines, the 1994 Vaccines for Children Program that provides no-cost vaccines to low-income children and the school mandates, Big Pharma has achieved nearly full saturation of the pediatric market, Kanthak said.

But that’s not the case for the adult market, where vaccine uptake is much lower without mandates. “Eliminating school exemptions for children is a major step in making exemptions unavailable for adults,” Kanthak said.

Because the child market was already saturated, “they [pharma] couldn’t use low rates as an excuse” to argue legislators should eliminate access to exemptions, he said.

That has resulted in the misrepresentation of vaccine rates, where it is made to seem as if high numbers of children are missing required vaccines, raising the specter of disease outbreaks, said Kanthak, which is apparent in the audit and EdSource’s reporting on it and most media headlines about vaccines.

“So you get policy influenced by headline,” he said.

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Audit numbers are ‘misleading’

For example, Kanthak told The Defender that many shots required for kindergarteners, including the last doses of the MMR, varicella, DTaP and polio can be administered between the ages of 4 and 6, according to the CDC’s childhood immunization schedule.

Doctors or parents planning to complete the course of vaccination may choose to do so later in that time period for any number of reasons related to the child’s development, health condition or previous vaccination.

Because children start kindergarten in that window, many children being counted as unvaccinated are on the CDC schedule, even if they are not yet “fully vaccinated,” he said.

“To count conditional admissions as unvaccinated is misleading,” he said.

“The tracking systems are not designed to track students who are simply still ‘in process’ with pediatricians who are following the medical guidelines and individualizing care to the patient,” he said.

Instead, “The schools are measuring too-young students, too early in the school year, for injections they are not overdue for until second grade.”

Kanthak said the audit numbers themselves are misleading because some of the schools listed have very few students and some of those students are missing something marginal.

“The first two schools on the list have only two seventh grade students, therefore one student missing their Tdap — sixth pertussis injection — gives those schools an only ‘50% fully vaccinated’ measurement.”

The audit lists a significant number of schools with very few students. Sixty-three elementary schools and 53 seventh grade schools have fewer than nine students. Thirty-five elementary schools and nineteen seventh grade schools have fewer than 20 students.

In those schools, having one or two students not “fully vaccinated” places them on the audit list, but it is a small number of overall students. Using a percentage in any population less than 100 is misleading, he added, because each student comprises more than 1% of the total.

Kanthak added that such reports typically exclude these small numbers to protect children’s confidentiality.

Only 61 of the kindergarten schools on the list and 46 of the seventh grade schools on the list had more than 100 students.

Overall, the total number of kindergarten students in the more than 500 schools on the audit list comprises about 5.3% of the total 471,379 kindergarten students in California.

California-based attorney Brad Hakala of the Hakala Law Group told The Defender, “In a state that has in excess of 39 million residents … it seems like statistics are consistently being skewed” to favor the position that dropping vaccine rates is a crisis.

“With that said, and in light of parental rights which more and more parents are attempting to exercise,” he added:

“There certainly seems to be a growing concern among parents … who are avoiding or delaying the vaccination of their child/children for one reason or another. …

“Some parents are not fundamentally opposed to the traditional vaccines being administered to their children, but they just want to space them out in frequency, timing, and volume, especially in light of ongoing concerns of vaccine injuries. Others want a more holistic approach and are opposed to their children having any vaccinations.

“I believe that the pandemic, the emergency use authorized (EUA) shots and the ever-increasing negative health ramifications that we are seeing arise from these untested medications that are still under EUA, are highlighting the already growing concern that parents are having with injecting their children with more and more medications.

“From the requisite number of injections and vaccines significantly increasing over the years, to the way that society has been treated by varying governmental entities since 2020, parents just want to protect their children and have the absolute right to protect their children, and I personally think that is having an overall effect on the current vaccination rates within California.”

Vaccine rights attorney Greg Glaser told The Defender he thinks the rising concerns parents have with vaccination has the potential to pose a real threat to Big Pharma, which is “calling the shots” on these audits to make sure vaccination rates don’t drop at all.

“The pharmaceutical companies fund the politicians and then the politicians put pressure on the Department of Public Health,” he said. “The first lever they’re able to control is these public health officers and public health departments.”

“Vaccine hesitancy scares Big Pharma,” he said.

He added:

“Pharma is very sensitive to trends. They can see when parents are no longer choosing vaccination and they know what a trend looks like. …

“Pharma’s clearly seeing a trend that less parents are vaccinating. So they’re using their levers of power in public health departments to audit schools to stop that trend.”

Ad hoc immunization clinics raise concerns

EdSource reports that schools and districts trying to increase vaccination rates are sending vaccination guidelines home with students and health services teams and reaching out to families to let them know where to get vaccinated.

Also, some schools or school districts are offering immunization clinics.

For example, Sacramento City Unified School District offers weekly free vaccination clinics at its district enrollment center. And Gateway Community Charters offered a clinic at its middle school.

The presence of such clinics also raises concerns, Glaser said, specially given the recent push by the U.S. federal government to rapidly expand the use of school-based health centers across the country.

This push has some critics concerned children will receive, or be pressured into receiving, unnecessary or unwanted medical interventions without their parents’ knowledge or consent.

Dr. Mary Kelly Sutton — an integrative physician whose license was revoked by the California medical board for writing eight vaccine medical exemptions the board alleges were not fully compliant with CDC regulations — told The Defender she saw the clinics as a way to pressure families and children into vaccination in ways that could violate their rights.

“Schools are not medical offices, and the records on vaccines are not complete, so some children will get vaccines they do not need,” she said.

Sutton added, “Many questions must be asked: how is permission obtained? How is the vaccination transmitted to the child’s chart in the real doctor’s office? How are adverse events handled medically and financially?”

Vaccine exemptions: ‘as California goes, so goes the nation’

California has been ground zero for struggles over vaccine mandates for over a decade.

In 2012, California passed Assembly Bill 2109 to restrict the ability of parents to have their children exempted from vaccine requirements based on personal beliefs.

Where before parents simply had to write a letter stating their personal beliefs, the new law stipulated that parents seeking exemption for their children must get the signature of an authorized healthcare provider stating that parents had received information about the risks of not being vaccinated.

In 2015, allegedly prompted by a measles outbreak at Disneyland — that the media blamed on unvaccinated children — and low vaccination rates in many California schools, Democratic State Sens. Richard Pan and Ben Allen authored a controversial bill, Senate Bill 277, that eliminated the “personal belief exemption” altogether.

Pan’s SB 277 passed in 2015 and Gov. Jerry Brown signed it into law, despite significant pushback from parents, hundreds of whom protested at the legislature.

During the COVID-19 pandemic, Pan also proposed legislation mandating the COVID-19 vaccine for all school children, with no personal or religious exemptions permitted — before the full approval of the vaccine for children by the U.S. Food and Drug Administration. The bill did not pass.

He also wrote a 2021 op-ed in The Washington Post likening “anti-vaccine extremism” to domestic terrorism.

The passage of SB 277 in 2015 made California the first state in nearly 35 years to eliminate nonmedical vaccine exemptions. Beginning in January 2016, nonmedical vaccine exemptions were no longer accepted for school entry.

After that, school vaccination rates rose. Parents who don’t want to vaccinate their children can obtain a medical exemption, have their children enrolled in special education services or homeschool them.

California has one of the highest rates of homeschooled children in the country, and those numbers are higher post-pandemic.

But California has also taken an aggressive stance against medical exemptions.

Doctors providing medical exemptions have been investigated by the California Medical Board, with many of them having their licenses revoked.

All medical exemptions for California children issued on or after Jan. 1, 2021, are subject to review by CDPH and can be revoked. All exemptions are automatically reviewed if they are submitted in a school where the immunization rate is below 95% if the school has failed to report its vaccination rates, if the physician writing the exemption has written more than five medical exemptions in a calendar year or if CDPH deems it necessary to protect public health.

As a result, Glaser said, “the number of medical exemptions in California has slowed to a trickle.” And those rules, he said, were put in place by Pan “for political reasons, not for reasons of public health.”

Glaser also said he thought these audits were happening in California because “as California goes, so goes the nation.”

He added, “When something is tried and succeeds in California, according to the metrics set by those in power, then they have a justification to roll it out across the nation.”

Hakala thinks that since 2020, “an increasing portion of the population is growing in their concern for what messages and information the government is putting forth, and the laws that are being passed that affect parental rights, especially in California.”

He added:

“I think there’s a growing distrust for the veracity of the information that is being disseminated, and on the basis of the laws that are being passed — and not just by one side of the political aisle or the other — but all information being disseminated seems to be increasingly scrutinized, as society’s skepticism continues to grow.

“This, in part, I think has a direct effect on the numbers that the audit report exemplifies.

“The public’s trust seems to be consistently evaporating, and it is my belief that a significant amount of work will need to be done to repair that trust.”

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