Student and Resident Immunization and Tuberculosis Screening

General Background

Society at large has a stake in reducing the incidence of preventable infectious diseases. An outbreak of measles, for example, causes immediate physical suffering and economic and educational harm in the form of lost days of work and school. An outbreak also may result in long-term adverse physical consequences for those afflicted.

In an effort to reduce the incidence of preventable infectious disease within the State, the Ohio Department of Health recommends that each citizen receive the following immunizations and screening:

1. At least three (3) doses of a vaccine containing protection against tetanus and diphtheria given to infants as a series of diphtheria, tetanus and pertussis (DPT) or to adults as a TDap booster, and
2. Three (3) doses of oral polio vaccine (OPV) to be administered up to the 18th birthday or four (4) doses of inactivated polio vaccine (IPV); and
3. Immunization against measles, mumps and rubella (MMR) with two (2) doses of the MMR vaccine to be administered to students prior to entering the seventh grade; and
4. A current tuberculin skin test (Tb) or a recent chest x-ray.

The immunization standards set forth above have the force of law where the citizen is a school-aged child. Ohio Revised Code Section 3313.671 requires elementary and high school pupils to be immunized against mumps, poliomyelitis, diphtheria, pertussis, tetanus, rubeola and rubella. The statute also requires certain public entities to provide, at public expense, the means of immunization against the above to pupils whose parents do not so provide.

Officials of post-secondary educational institutions also have a stake in reducing the incidence of preventable infectious disease. The economic and social costs associated with an outbreak of campus of a "childhood" disease or of tuberculosis are significant. An outbreak requires campus officials to quickly implement mass programs of testing and immunization. The panic associated with an outbreak extracts an emotional toll on students and also distracts members of the faculty and staff from their primary responsibilities. The adverse publicity associated with an outbreak easily can outlive the outbreak itself.

In light of the above costs, university officials have obligations to both the campus and broader communities to reduce the risk of preventable infectious diseases. These dual obligations necessitate policy development, education, and policy enforcement.

Definitions

1. "University residential student's shall mean any degree-seeking or non-degree undergraduate or graduate student who is a party to a residence agreement with the university.
2. "Program participant resident" shall mean any participant in a university sponsored educational, athletic, or cultural program who, as part of the program, chooses to live in a university owned or managed residential facility. The term "program participant resident" includes, but is not limited to, persons participating in the pre-college, Upward Bound, and international exchange programs and sport cam participants.
3. "Guest resident shall mean any person who temporarily resides in a room in a university owned or managed residential facility without the benefit of a residence agreement and who is not a university residential student or a program participant resident. The term "guest resident" includes, but is not limited to, visiting faculty and students from other institutions of higher education interning at sites adjacent to the university.
4. "International student" shall mean any degree-seeking or non-degree undergraduate or graduate student who is a citizen of a country other than the United States of America.
5. "Student" shall mean any student covered by the Policy and shall include university residential students and international students.
6. "Resident" shall mean any person residing in a university owned or managed residential facility and shall include university residential students, program participant residents, and guest residents.
7. "University residential facility" shall mean any university owned or managed residential facility designed to house persons.
8. "Health Care Provider" shall mean the primary physician of a student or nurse practioner with access to the medical records of the student or resident.
9. "Prospective student" shall mean any person who has applied for admission to the university as a degree or non-degree undergraduate or graduate student but who has not yet been admitted.
10. "Prospective program participant" shall mean any person who has applied for admission to a university sponsored educational, athletic, or cultural program but who has not yet been accepted.
11. "Prospective guest resident" shall mean any person who has made a reservation for guest housing in a university owned or managed residential facility.
12. "Screening" shall mean the results of a current tuberculin tine test or a recent chest x-ray indicating that the student or resident is free from tuberculosis.
13. "Certification" shall mean a statement from a physician indicating that the immunizations of a student or resident are in conformance with the requirements imposed by this Policy and that the student or resident is free from tuberculosis.

Populations at Risk

Students and residents present on the Wright State University campus vary in the (1) risk they present to the campus community for the introduction of preventable infectious disease and (2) the degree to which they are at risk should an outbreak of any preventable infectious disease occur. Four populations present relatively high levels of risk, either to others or to themselves:

1. University residential students living in university owned or managed residential facilities; and
2. Program participant residents living in university owned or managed residential facilities for a period of time exceeding fourteen (14) days, inclusive of intervening weekends; and
3. Guest residents living in other than single rooms in university owned or managed facilities for a period of time exceeding fourteen (14) days, inclusive of intervening weekends; and
4. International students both undergraduate and graduate enrolled at the university.
5. An unimmunized university residential student living in campus housing presents an unacceptable level of risk to self and others. Most campus housing units are other than single occupancy, resulting in significant opportunities for the transmission of germs through the air, eating and drinking utensils, food products, discarded facial tissues, and personal by-products. The university, as a party to a residence agreement, has an obligation to act reasonably to reduce the risks associated with on-campus residence life. For university residential students, the risk evolves primarily from the setting in which the students live and interact.
6. Similarly at risk are program participant residents, many of whom are elementary or secondary school students participating in pre-college programs. The risk presented by this group may even be higher than the risk associated with university residential students because the acquired immunities of the pre-college student are less well-developed than their college-age counterparts. As with university residential students, the primary risk associated with the group arises as a by-product from the group living setting created by the university.
7. Any unimmunized person who lives temporarily in other than a single room in a university residential facility also may present a health risk to a roommate or may be vulnerable to the health risks created by an unimmunized roommate. The university as the provider of lodging has a duty to act reasonable to reduce the risks to which its quests are exposed.
8. International undergraduate and graduate students present a significant level of risk for the introduction and spread of preventable infectious disease. This risk is present even when the student lives other than on-campus because the risk derives from the student rather than the setting. Even though some countries have immunization policy and enforcement comparable to that found in the United States, the majority of countries do not. As a result, a citizen of another country coming to the United States for study is less likely to be immunized than his or her United States counterpart. In addition, the opportunities for exposure to tuberculosis are far greater outside the United States than within.
    

General Policy

The Division of Student Affairs, in order to protect the health and well-being of all members of the Wright State University community, and cognizant of the special circumstances surrounding residential and international students, hereby sets forth the following policy on student and resident immunization and tuberculosis screening (the "Policy").

Each university residential student, program participant resident, guest resident and international student shall be required to present evidence, in the form, of certification by a licensed healthcare provider, that:

1. The student or resident has been immunized against measles, poliomyelitis, diphtheria, pertussis, tetanus, rubeola and rubella (immunization certification); and
2. An international student from a high risk country is free of tuberculosis

The university hereby incorporates into this Policy, and adopts as a definitive statement of the minimal requirements for immunization and tuberculosis screening, the recommendations of the Ohio State department of Health as set forth in number 1. (General Background).

In the case of immunization certification, the healthcare provider shall certify that the student or resident has been immunized for each of the diseases mentioned above and shall specify the date of each such immunization or booster. In the case of certification regarding tuberculosis, the healthcare provider shall certify that (1) the result of a tuberculin skin test, IGRA (Interferon-Gamma Release Assays) or chest x-ray is negative, (2) the result of a tuberculin skin test is positive but a chest x-ray shows no evidence of tuberculosis, or (3) the student or resident has active tuberculosis but is in treatment, is compliant, and the symptoms and laboratory reports of the student or resident indicate that the treatment is effective.

The certifications required by the Policy for university residential students shall be presented to the university no later than the first day of classes of the first semester for which the student desires to live in a university owned or managed residential facility. For international students, certification shall be presented no later than the first day of classes of the first semester for which the student desires to enroll at the university. For program participant residents, certification shall be provided no later than the 10 working days prior to the first day of the university-sponsored program in which the program participant resident desires to participate. For guest residents, certification shall be provided no later than 10 working days prior to the first day of the period in which the guest resident desires to live in a university residential facility.

A university residential student or international student who fails to present the certifications called for in this Policy prior to the first day of classes of the applicable semester shall be encouraged to comply with the Policy but will be permitted to attend classes or live in a university owned or managed residential facility or both for the remainder of the applicable semester while the policy requirements are met. Prior to the date upon which the following semester's registration materials are distributed, however, a hold shall be placed on the registration of the student which will prevent the student from registering for and attending classes in the following semester and from residing in a university owned or managed facility until such time as the requirements of the Policy are met.

A prospective program participant resident who fails to present the certifications called for in this Policy shall not be permitted to participate in the university sponsored program for which application has been made if program participation requires residence in a university residential facility. A prospective guest resident who fails to present the certifications called for in this Policy shall not be permitted to move into a university residential facility.

The expense of any immunization, screening, or treatment required to bring the student or resident into conformance with the requirements of this Policy shall be borne by the student or resident or, if the student or resident is a minor, by the parent(s) or guardian(s) of the student or resident. The Student Health Services may, at its discretion, establish a program of testing, immunization, screening, or treatment as a service to students and residents but is in no respect required to do so.

Starting July 1, 2005, the State of Ohio will enact a bill that states that college students who live in campus housing will be required to fill out a form stating they have received information about the benefits of being immunized against bacterial meningitis and hepatitis B.  They, or their parents if under the age of 18, will then complete a questionnaire asking them to state if they have, or have not been immunized against bacterial meningitis or hepatitis B.  This form must be completed prior to being allowed to live in campus housing.

The Wright State University Student Health Services, under the guidance of its director, shall have primary responsibility for implementing and enforcing this Policy.

Effective Date

This Policy shall be effective for an apply to each university residential student entering into a residence agreement for the summer quarter 1995 or any academic term thereafter; to any international student admitted for the first time to the university for the summer quarter 1995 or any academic term thereafter; and to any prospective program participant resident seeking admission to any university sponsored program beginning June 12, 1995 or thereafter; and to any prospective guest resident seeking temporary housing in a university residential facility beginning June 12, 1995 or thereafter.

Policy Implementation

Student Health Services shall have primary responsibility for implementing, administering and enforcing the Policy. Student Health Services also shall have primary responsibility for maintenance and retention of all records created pursuant to the Policy in keeping with the university's records management and retention program.

Student Health Services shall develop a form (hereafter referred to in this Policy as the "Form") which, when properly and fully completed, will meet the requirements of this Policy. The Form shall consist of at least two parts. The first part, addressing immunization history, shall be designed to be completed by the physician of the student or resident and shall require the physician to certify the specific date of administration of each required immunization or booster.

The Form also shall clearly state that the physician's certification is required for university residential students, program participant residents, quest residents, and international students and that the Form is to be returned to Student Health Services for evaluation. The Form also may include, at the discretion of Student Health Services, other parts or sections not related to immunization.

Student Health Services shall be responsible for ensuring that a copy of the Form is made available to each prospective university residential student, program participant resident, guest resident and international student. Student Health Services may seek the cooperation of other university offices and personnel in the distribution of the Form but primary responsibility for distributing the Form shall rest with Student Health Services.

Student Health Services shall receive all completed Forms and review each for conformance with the requirements imposed by this Policy.  Review shall be conducted by a student health staff.

Student Health Services shall, in a timely fashion: (1) initiate contact with each prospective student or resident who has failed to timely submit a properly completed Form or who has submitted a Form indicating that either the immunizations or tuberculosis screening or treatment results or both are not in conformance with the requirements of this Policy and (2) inform each such prospective student or resident that failure to submit the Form or to obtain the required immunizations or tuberculosis screening or treatment or both shall result in the placement of a hold on the university residential or international student's registration for the succeeding semester, the denial of admission to a prospective program participant resident, or the termination of the guest registration of a prospective guest resident.

Student Health Services shall be responsible for placing a hold on the following semester's registration of any university residential or international student who has failed to submit a properly completed Form or who has submitted a Form indicating that either the student's immunizations or tuberculosis screening or treatment results or both are not in conformance with the requirements of this Policy. Student Health Services also shall be responsible for timely notifying the administrator of any university sponsored program that the immunizations or tuberculosis screening or treatment results, or both, of a prospective program participant resident are not in conformance with this Policy and that the student may not participate in the program to which the student has applied if participation requires housing in a university residential facility. Finally, Student Health Services shall be responsible for timely notifying the Office of Residence Services that the immunizations of a prospective guest resident are not in conformance with this Policy and that the prospective guest resident may not move into a university residential facility.