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Greg Siskind on Immigration Law and Policy

WHITE HOUSE ON THE DEFENSIVE OVER NEW HPV VACCINE REQUIREMENT FOR GREEN CARD APPLICANTS

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When the cable news shows are talking about it, you know something's up. In July, USCIS began requiring female immigrants between 11 and 26 to get a vaccine to prevent the Human Papillomavirus (HPV), a virus that is usually sexually transmitted. The agency discussed this new requirement in a recent public forum:

Question: There is some concern among both CBOs and civil surgeons regarding the new requirement on the I-693, Report of Medical Examination and Vaccination Record, to receive the HPV vaccine. Is the HPV vaccine recommended or required? If required, who is required to take the vaccine? Also, are applicants required to just take the initial dose for the purposes of the I-693, or must they complete the series?

Response: The human papillomavirus (HPV) vaccine is one of several new age-specific required vaccinations that have been added to the Technical Instructions for Vaccination for civil surgeons conducting medical examinations of aliens. These newly added vaccination requirements, effective July 1, 2008, were a result of recommendations from the U.S. Advisory Committee on Immunization Practices (ACIP) and are required for persons to be medically cleared for adjustment of status. As a reminder, Health and Human Services/Centers for Disease Control have the regulatory authority to set the
www.uscis.gov requirements for our medical exams and we are bound to these requirements. As such, any vaccination recommendation made by the ACIP for persons living within the U.S. becomes a requirement for immigrants.

The HPV vaccine is required for females ages 11 through 26 years of age. As with all the vaccinations, because completion of a vaccine series often takes several months, applicants are currently not required to complete a series before being medically cleared to proceed with adjustment of status. They must, however, complete as many doses as was medically appropriate at the time the medical exam was conducted and are encouraged to follow-up with their primary physicians at a later date to finish any series. Further information and updates on the required medical exam and vaccines can be accessed at www.cdc.gov/ncidod/dq/health.htm.

What's the big deal? Well, I won't get in to the issues of whether the vaccine has had complications. Though there have been complaints, let's just assume that the drug is, on the whole, a good one that will deliver important public health benefits.



The more serious argument is probably the one involving costs. The one HPV vaccine available, Merck's Gardasil, costs $162 per dose and three shots are required. It's the most expensive vaccine on the market today and if you don't have insurance, you're talking about almost $500. That's a new cost that can be a serious impediment to many thinking about filing for permanent residency.



While I generally support the notion that immigrants should not be subsidized in terms of covering the costs of processing their immigration applications, this seems to be excessive. Perhaps the compromise would be for the US government to buy up the drug and use its buying power to command a substantial discount and then offer the vaccine at a discount.



Second, the drug has apparently caused numerous complications, though I don't think there is serious disagreement that on the whole

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