Getting started with health law quickly: Immunization registry information system | Dentons


Q: Our healthcare facility has just started enforcing vaccines and we are finding that a number of our employees have misplaced their vaccination cards. Our establishment is an authorized user of IRIS (Immunization Registry Information System) can we use it to check if the employee has been vaccinated?

A: Yes, but you need an employee consent form.

IRIS is not intended for use by employers to check employee health records, although it may be used as part of an employee health program.

As an authorized user of the site, your organization would have signed an authorized site agreement that requires you to comply with all IRIS requirements, including their privacy and security policies. The site agreement itself states that the facility “will only have access to immunization and other screening information in IRIS for people to whom the organization provides services or is required to legally perform a function. authorized of the organization ”. The IDPH said this may include a general employee vaccine check to help employees complete all vaccines and identify vaccine gaps.

Also note that IRIS’s security and privacy policies state that “The information contained in IRIS is confidential under Iowa law. Registered users should not disclose vaccination or health screening data obtained from the registry except to the vaccinated or screened person, the parent or legal guardian of the vaccinated or screened person, admitting daycare officials and accredited schools, medical or health care providers ensuring continuity of care, and other registered users of the registry. However, based on these statements, if an employee could not produce a vaccine registration card and requested access to IRIS data, an employee consent form could be obtained which would be kept on file. employee’s health and allow the establishment to access the IRIS system based on this request.

Consent forms found online are primarily access requests to the state, any consent obtained from an employee must expressly consent to access the vaccine database and registry.

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