Testimony Before the Council of the District of Columbia Committee of the Whole at the Public Roundtable on: “No Shots, No School” for School year 2022-2023

Oct 12, 2022

Good afternoon, Chairman Mendelson and members of the Committee. My name is Rachel Johnston and I am the Senior Director of Operations and School Support at the DC Charter School Alliance, the local non-profit that advocates on behalf of public charter schools to ensure that every student can choose high-quality public schools that prepare them for lifelong success.

I’ve been in constant contact with our LEAs and I can confidently say that they are deeply committed to making sure the nearly half of DC public school students they serve are learning in safe and nurturing environments. They understand the importance of routine immunizations, and have made an extraordinary effort, particularly over the summer, to get students in compliance with ‘No Shots, No School.’ This includes engaging in outreach to families, hosting numerous vaccine clinics, and deciphering less than perfect data.

But, as we testified earlier this year, enforcing ‘No Shots, No School’ risks excluding thousands of students from attending school and creating a huge educational equity issue for schools and families to navigate as a result of unreliable data and systems and unclear, inconsistent information and messaging. Charter schools have put so much time and effort into academic recovery, and excluding thousands of students across the city only undermines that process.

Unreliable Systems and Inaccurate Data

I want to start by acknowledging and thanking Superintendent Christina Grant and the staff of the Office of the State Superintendent of Education (OSSE) who have worked diligently to support LEAs in navigating data issues across DC Health’s many immunization systems.

Earlier this year, we raised the alarm about the need for user-friendly data from the city on immunization compliance, as well as accuracy issues with reports from DC Health’s District of Columbia Immunization Information System (DOCIIS) 2.0, making it difficult to trust its validity. Unfortunately, those issues have not been resolved, and the overwhelming burden of tracking compliance has fallen to our schools. For example, when DC Health realized DOCIIS 2.0 was not accurately reporting compliance rates, it created another system, the Salesforce Immunization Compliance Portal, for LEAs to use. LEAs needed to then learn and access yet another system to track compliance and target family outreach. Indeed, currently LEAs must navigate four separate data systems while seeking to ensure compliance with No Shots, No School requirements. Some of our LEAs are still lacking access to at least one of the systems.

School leaders have reported that DC Health’s data systems continually have glitches and cannot be relied on, and as a result, many are maintaining their own databases. In what appears to be a tacit admission that DC Health’s data is flawed, the city has repeatedly asked schools to report out how many students are at risk of exclusion. The countless hours schools spend deciphering bad data takes away time and resources from what schools should be focusing on: educating students.

Additionally, when schools don’t have accurate data to understand their compliance rates, family engagement efforts can be severely damaged. Schools rely on this data to strategically target their communications. When DC Health’s data systems don’t accurately reflect that a student has met vaccination requirements, and then schools reach out to that family asking them to get in compliance, it causes frustration and can damage trust between the family and school. Family engagement is always a top priority, but it’s even more important now as we enter the next phase of the pandemic, one with more time in school buildings.

Lack of Clear, Consistent, Centralized Information

In addition to unreliable systems and inaccurate data, our schools are also dealing with a lack of clear, consistent, and centralized information about ‘No Shots, No School’ and vaccine requirements. For example, when the city set October 11 as the date to exclude PreK-5 students not in compliance, charter schools were told they could use this date, or they could choose their own date. However, in one of the many forums where the city is providing updates on ‘No Shots, No School,’ it was stated that the exclusion date was October 11, period. The mixed messages from different city agencies are confusing and put schools in a difficult position of trying to decipher a very important policy.

To help alleviate the burden this has placed on our schools, the DC Charter School Alliance has stepped in and created a brief, but comprehensive resource tracking the updates received through calls, newsletters, emails, and other forums into one centralized location. This is something that the city should be doing, but instead we’ve taken on that role to make sure our schools can navigate the confusion.

Lack of Clear, Transparent Messaging

We also raised the alarm earlier this year about the lack of clear, transparent messaging about vaccination requirements. This presents a problem. If families are receiving competing messages from their schools and from the city, how can we expect them to fully comply with ‘No Shots, No School’ requirements? For example, what is considered fully vaccinated against COVID-19? Is the original one- or two-shot series sufficient, or does it also include boosters? That’s currently not happening, to the detriment of our families and our schools.

Education Equity in Enforcing ‘No Shots, No School’

Based on estimates from various city agencies, the current number of public school students not in compliance with ‘No Shots, No School’ could be nearly 20,000. If forced to exclude students not in compliance, school leaders might be excluding one in every five students from valuable instruction time. That is a staggering number.

In fact, our schools are so concerned about the potential legal risks for mass exclusion of students that the DC Alliance has been holding regular office hours to make legal experts available to help guide schools.

And we know that this burden will fall disproportionately on our most under-resourced communities. If schools exclude students, those students not only face yet another setback in their academic recovery, they also lose access to incredibly important wraparound services – things like after school programming, meals, and vital mental health services.

To be clear, charter school leaders believe in the very important goal of getting their students vaccinated – they’ve gone above and beyond to do the job our public health agency should be doing. But their top priority must be equitable educational access, not solving public health crises.

The burden for implementing policies the city enacts has repeatedly fallen to LEAs – adding to a long list of responsibilities school leaders already must manage. And while our schools are nimble, responsive, and innovative, they are not healthcare specialists, or policy implementation experts – nor should they be expected to be.


To address the myriad concerns we’ve raised today and throughout the last year on enforcing ‘No Shots, No School,’ we recommend three courses of action:

First, the city should revisit the exclusion requirement. Because of the documented challenges with data on vaccine compliance, the lack of clear, consistent information, and the significant equity implications, we feel strongly that if schools are required to move forward with excluding students, there will likely be a number of students improperly excluded. While our schools are doing everything possible to avoid that outcome, we cannot guarantee it won’t happen. Accordingly, some charter schools have chosen to hold off on notice letters and exclusion dates to make sure they aren’t making decisions based on inaccurate data.

Second, the city must make getting students in compliance with ‘No Shots, No School’ a truly citywide responsibility, and let schools be schools. The city must stop putting the burden of public health on LEAs. It’s the public health system’s job to make sure children receive routine vaccinations. It’s the public health system’s job to engage in large-scale education campaigns about the COVID-19 vaccine and boosters. And it’s the public health system’s job to increase the rate of up-take. It is more important now than ever, as schools invest deeply in academic recovery, that we let schools focus on what they are designed to do: educate children. Every hour spent deciphering bad data is an hour that is not spent on academics.

Third, the city should revisit COVID-19 vaccine requirements. We want every student to be vaccinated for COVID-19 because it will improve the health and safety of school communities and reduce the future burden of COVID-19 surges on schools. But right now, the compliance rate for students 12 and above, who are required to get the COVID-19 vaccine, is quite low, hovering around 45 percent. Poor public health messaging and misinformation about the vaccine’s effectiveness has led to extremely low uptake for these students – particularly for students at the fringes of our education system. We’ve also seen little to no public education campaign on the booster, which is geared toward protection against the most prevalent COVID-19 variant. This is clearly an untenable situation for our schools to be in. They want to encourage maximum protection for their students, but they cannot force parents to get their kids vaccinated. The answer cannot be just sitting on our hands and hoping vaccination rates go up. We encourage the city to rethink the vaccine requirements in light of this reality, and to engage in a massive public education campaign to make sure families are receiving accurate, updated information about the current state of the pandemic, the vaccine’s effectiveness at preventing serious illness, and staying up-to-date with boosters as necessary.

Moving Forward

The health and safety of charter school students is a top priority. But until the city becomes a true partner in the effort to increase vaccination rates, schools risk moving backward in their primary role – accelerating students’ learning and academic recovery. Revisiting the exclusion requirement, removing the burden of public health from schools, and rethinking COVID-19 vaccine requirements are three ways we can begin to accomplish our shared goals of meeting students’ health needs and their academic needs.

Thank you for your time and attention to this matter, and I welcome your questions.