Vaccinating foster youth not the top priority for CFSA

The COVID-19 vaccine has been approved for all children aged 12 and older and has been proven safe and effective. The Mayor has strongly encouraged all eligible youths to be vaccinated, organized special vaccination clinics in schools, and announced a variety of incentives for youth vaccinations. Children in foster care are wards of the District, and one might think that the agency would act as the Mayor has encouraged parents to do, and make vaccinating its wards the top priority. However, it appears that that for CFSA, vaccinating its youth falls somewhere below other priorities, such as protecting parents’ rights to refuse vaccinations for their children.

In the District of Columbia, all children aged eleven and up are allowed to consent to their own vaccinations under a new law, the Minor Consent for Vaccinations Amendment Act of 2020. However, in a new Administrative Issuance (AI) released on on July 22, CFSA takes pains to clarify that it has chosen not to take full advantage of this opportunity to get foster youth vaccinated. In the AI, titled “How to Obtain Informed Consent for COVID-19 Vaccination for Children Served in Out-of-Home Care,” CFSA states that “This law does not negate the Agency’s ability to first seek parental consent, rather, it provides an avenue for consent when a parent or caregiver does not consent.” The agency goes on to state that it has decided to continue obtaining parental consent for vaccination for youth 11-17 unless parental rights have been terminated. Youths aged 18-21, who are “developmentally capable,” are allowed to consent to their own vaccine.

Given that CFSA has decided to request consent from all parents of children under 18, the agency could have required social workers to ask all parents of children in their caseloads to consent to the COVID-19 vaccine for their eligible children by a certain date. But they did not do so. Instead, the AI states that “Social workers will ensure that parents receive the share (sic) “Fact Sheet for Recipients and Caregivers” before obtaining their consent to ensure they are making an informed decision about their child receiving the COVID-19 vaccine.” Thus, the focus is on ensuring that social workers share the fact sheet if they request consent, rather than requiring that they ask all parents to consent to the vaccination for their children. Moreover, there is no requirements that these conversations be documented so that the agency can determine how many parents have been asked and how many have agreed; documentation is required only when parents “refuse or are unable to provide consent.”

We do not know how proactive the agency is being in requesting parental consent for children aged 12-17 to receive the COVID-19 vaccination. According to Kera Tyler, CFSA’s Communications Director, “our social workers are actively encouraging parental consent for the vaccine for children in care over the age of 11. By sharing relevant educational materials along with District incentives, our Parent Engagement Education and Resource (PEER), family support workers, and social workers are facilitating conversations with both birth and resource parents to support vaccination for youth 12 and older.” The emphasis on educating parents and using peer support workers is laudable. But with no record of how many parents are being reached with such communication and what the results were, there is no way to know how successful these efforts have been.

The AI does provide a procedure for a child aged 17 or under who wants to get vaccinated to consent to the vaccine if the agency has not obtained parental consent for whatever reason. In such a case, “CFSA will ensure that the child meets with their primary care provider,” according to the AI. The social worker must “ensure that age and developmentally appropriate information about the COVID-19 vaccine is provided to the child by the primary care provider…The primary care provider must confirm that the child understands that they are making an informed decision about their consent to receive the vaccine.” And If the child does consent to the vaccine, “the primary care provider will be responsible for arranging and administering, recommending, or prescribing the vaccine.”

This is a rather cumbersome procedure. The extra step of seeing the primary care provider is not required of other District children consenting to their own vaccinations. Arranging and carrying out this visit is a burden for already taxed social workers. It is not even clear that primary care providers are willing to schedule such appointments. In any case, following this procedure is sure to delay vaccination. Perhaps most importantly, this provision makes it harder for young people in foster care than for their peers who are not in foster care to consent to their own vaccinations. One has to wonder if any children have been vaccinated under this provision, but CFSA has not been collecting vaccination data, as discussed below.

The situation is different for foster youth aged 18 to 21. According to the AI, these young people can consent to vaccinations unless they have a mental disability. The AI states that “Social workers will ensure that youth receive the share (sic) “Fact Sheet for Recipients and Caregivers” before obtaining their consent to ensure they are making an informed decision about receiving the COVID-19 vaccine.” Again, the instructions are more about ensuring that social workers share the fact sheet if they do request consent, rather than requiring that they make this request of all youth in this age category. And without a documentation requirement, we have no idea about how often these conversations are being held and what the results have been.

As with parents, CFSA cannot document how proactive it is being in requesting consent for vaccination from older youth in foster care. According to Tyler, “For our older youth, CFSA social workers have distributed educational materials to youth on their caseloads, coordinated appointments, arranged transportation to and from vaccination sites, and promoted the District’s incentives as applicable.” I mentor a nineteen-year-old in foster care who was eligible early for the vaccine early based on medical status, and it was I who provided information about the vaccine, helped her obtain her appointments and drove her to both. She reported that her social worker “mentioned” the vaccine, but there was no offer of assistance in getting vaccinated.

Given the procedures restricting vaccine uptake among CFSA children aged 12 to 17 and the lack of guidance about vaccine among older youth, it is important to know how many youths in CFSA care have been vaccinated. Unfortunately, the agency is not collecting this information. This makes it impossible to know how successful their attempts at obtaining consent have been. CFSA is collecting reports of children who receive a positive diagnosis of COVID-19 but given that these diagnoses are medical data, Tyler states that CFSA is developing some quality control standards before making those figures public.

It is perhaps not surprising that CFSA is sensitive to the beliefs of parents and older youths about COVID vaccines. Most foster youths are Black and vaccine hesitancy is high in the Black community. This hesitancy and the misinformation on which it is based is indeed the biggest barrier to getting older youths vaccinated, according to the Chairperson of the Board of Directors of FAPAC, an organization representing foster parents in DC. It makes sense to focus on sharing educational materials along with incentives to encourage vaccination among foster youth.

But the health of our foster youth, foster parents, and the District of Columbia population overall should be the top priority during this critical time, and CFSA should spare no effort in ensuring that all youth get the necessary information, and that all who are ready to be vaccinated can get the vaccine without delay. We know that foster youths have more health problems than their peers who are not in foster care, some of which put them at high risk if they develop COVID-19. Children’s National Medical Center has reported a “dramatic increase” in pediatric COVID-19 cases over the summer, fueled by the Delta variant. Nationally, cases in children have reached the highest level since the start of the pandemic–more than a quarter of all new weekly cases.

There were 624 children in foster care in the District of Columbia as of June 30, 2021.  More than half of these are 12 and older.* This is a small number relative to the total number of children in the District, but these children are under the District’s direct care. The Mayor has made vaccinations a priority for all eligible groups. One might hope that the District would set an example by making vaccination of its wards a top priority.

*According to the CFSA Data Dashboard, 47 percent of CFSA youth were aged 13 to 21 in the third quarter ending June 30; therefore it is likely that at least half of these youth were aged 12 to 21.