[co-author: Erin Howard]

On August 19, 2021, Connecticut Governor Ned Lamont issued Executive Order No. 13C (the “Order”) to expand access to COVID-19 vaccination information for patients and providers (and school nurses) as public health authorities continue to promote vaccination efforts, implement recommendations for vaccine booster shots, and as schools adopt COVID-19 control measures for returning students and staff. The Order modifies Connecticut law to allow the Commissioner of Public Health to disclose information reported to the Department of Public Health regarding a COVID-19 vaccine recipient’s immunization information– i.e., information in the state COVID-19 immunization registry – to:

• a health care provider of a vaccine recipient or potential vaccine recipient;
• each school nurse at a public or private school in any town, city or school district; and
• local health directors and other public health authorities to support COVID-19 vaccination efforts within their jurisdictions.

The Order defines “health care provider” to include physicians, advanced practice registered nurses, and physician assistants licensed by the Department of Public Health, as well as any health care organization that is providing COVID-19 vaccines under a Center for Disease Control and Prevention COVID-19 Vaccination Program Provider Agreement or any officer, employee or agent thereof acting in the course and scope of his or her employment. The release of this COVID-19 immunization information must be for the purposes of reducing the spread of COVID-19 and increasing access, use, and the provision of COVID-19 vaccines. The Order also grants the Commissioner authority to issue policies and procedures necessary to administer the disclosure of COVID-19 immunization information in accordance with the Order, including the way in which such information will be disclosed to vaccine recipients.

According to a press release issued by Governor Lamont announcing the Order, the changes are intended to align access to vaccine information in Connecticut with approaches taken in at least 37 other states, including New Jersey, New York, and Rhode Island. The press release also states that the Order “will allow individuals to easily and securely access their own COVID-19 vaccine record” and suggests that the Order will remove current barriers for patients seeking to access their own COVID-19 vaccination record.

Notably, the Order takes effect immediately but will only remain in effect through September 30, 2021 unless it is earlier modified or terminated.

*This post was co-authored by Erin Howard, legal intern at Robinson+Cole. Erin is not yet admitted to practice law.

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