Immunizations and California Optometry

Are you interested in providing immunizations to your patients? With the passage of Assembly Bill 443 in 2017 and Senate Bill 762 in 2018, California law allows optometrists to become certified to perform three immunizations—influenza, herpes zoster virus, and pneumococcus—on adults eighteen years and older.

The training for immunization certification has three requirements:

1. Optometrists will need to complete an immunization training program that is endorsed by the federal Center for Disease Control and Prevention (CDC) or the Accreditation Council for Pharmacy Education that, at a minimum, includes hands-on injection technique, clinical evaluation of indications and contraindications of vaccines, and the recognition and treatment of emergency reactions to vaccines.

2. Optometrists will need to maintain basic life support certification.

3. Optometrists will need to perform one hour of ongoing continuing education focused on immunizations and vaccines from an approved provider once every two years.

After successfully completing the immunization training, the OD applies for an immunization certificate on a board-approved form. This is where the paradox begins.

According to a notice circulated to practicing California OD’s from the California State Board of Optometry on May 10, 2019, the California State Board writes that, “At present, the Board is not accepting applications, course completion certificates or payments for the immunization certification. Immunization applications and payments sent to the Board will not be processed and will be returned to the licensee. The Board is not allowed to accept these until regulation implementing AB 443 becomes law (anticipated Spring of 2020).”

The notice concludes, “The final regulation, including the actual text and application form, will be made by the Office of Administrative Law (OAL), not the Board.”

The most common vaccination likely to be administered by California optometrists in the future is the influenza vaccine. Influenza (flu) vaccination is the primary way to prevent sickness and death caused by flu, and the CDC estimates that influenza was associated with more than 48.8 million illnesses, more than 22.7 million medical visits, 959,000 hospitalizations, and 79,400 deaths during the 2017-18 influenza season. This burden was higher than any season since the 2009 pandemic and serves as a reminder of how severe seasonal influenza can be. CDC estimates that from 2010-11 to 2017-18, influenza-associated deaths in the United States ranged from a low of 12,000 (during 2011-12) to a high of 79,400 (during 2017-18).

Among adults aged eighteen years and over, immunization coverage was 37.1% during 2017-18—6.2 percentage points lower than coverage during the 2016-17 season—with California adults having even less at 35.0%, according to the CDC website. Limited access to care is a factor in the low immunization coverage.

The 2018-19 statistics are yet to be published, and hopefully medical visits, hospitalizations, and deaths were less than the previous flu season. My question at this moment, and likely yours, is why bureaucratic obstacles are being announced by the California State Board of Optometry that prevent patient access to vital flu vaccines. California optometrists could be contributing during this year’s upcoming 2019-2020 flu season. Many OD’s have successfully completed their immunization courses, and they could be part of this season’s vaccination campaign. Instead, we are obliged to sit out and wait for OAL to write regulation. Senate Bill 762 contains some urgent wording that specifically states, “in order to protect the health and well-being of the public by allowing appropriately trained optometrists to administer immunizations, it is necessary for this act to take effect immediately.”

That being said, I recommend you, your family, and your staff each have an annual flu vaccine this month. In addition, consult the COA website for Immunization Certification Courses taught by optometry colleges at Western University of Health Sciences and SCCO at Marshall B. Ketchum University. Also on the COA website is a link for the next Pharmacy-based Immunization Delivery Course on November 2nd at UC San Diego, La Jolla.