For the fourth year in a row, its independent school auditor will tell the San Francisco Board of Education next week that the school district is out of compliance with state requirements to ensure that students are immunized before or shortly after being enrolled.
Last year, as The Voice of San Francisco reported, the independent auditor reviewed a representative sample of students and documented a compliance rate of 71 percent. In the current report, the auditor found that 81 percent of students sampled had complete immunization records — an improvement, but still out of compliance. With limited exemptions, California law requires all students to be immunized before enrolling. As in previous years, dating to 2022, the auditor names “administrative oversight” as the cause.
The school district first noticed the problem of lack of immunizations when students returned to school in fall 2021 after the Covid closures. In January 2022, the district’s Student and Family Services Division began to redesign its immunization compliance program and told the auditor that the reform would be implemented in August 2022. While the school district has reduced the number of auditor “out of compliance” findings in financial and other areas, repeated findings of noncompliance with public health requirements persist.
For the past three years, the auditor has recommended that the district assign a single person to ensure compliance. Each year, the district pledges to “assign a dedicated individual responsible for ensuring compliance,” but seemingly fails to do so. In response to a Voice of San Francisco request, school district spokeswoman Laura Dudnick stressed, “Beginning in summer 2025, Health Workers strengthened their partnership with the Enrollment Center to better support student health and community well-being,” but did not mention how the immunization program was being supervised or managed.
With limited exemptions, California law requires all students to be immunized before enrolling.
Compliance is becoming even more challenging for San Francisco schools. As a result of current budget reductions, the school district has assigned fewer nurses and health care workers to school sites, and they must now provide services to students and staff at multiple schools instead of one. The California Department of Public Health tracks schools that report to the state that more than 10 percent of kindergarten or seventh-grade students have been admitted despite not meeting their age-specific vaccination requirements. In 2024–25, the most recent period reported, the number of San Francisco schools on these lists has grown to 16 (10 elementary schools and six middle schools). The previous year it was 12. By comparison, the Oakland Unified School District has 34 schools on the list and, while the Los Angeles Unified School District has even more schools listed, its percentage of schools is smaller than San Francisco’s.
A school’s presence on the Public Health list is not necessarily evidence of a violation by itself. While children are supposed to be immunized before going to school, they are also entitled to a free public education. Schools may comply with the immunization requirement by collecting evidence of immunization at enrollment and by conditionally admitting, for up to 30 days, students who lack certification to give them time to become immunized. Being on the list, however, means oversight is particularly important at those schools so that other students are not exposed to the unimmunized student after the deadline has passed.
National factors also complicate immunization compliance. Newcomer students may shy away from public health immunizations to maintain a low profile. At the same time, recent anti-vaccination pronouncements by the U.S. Department of Health and Human Services Secretary Robert F. Kennedy, Jr. may also contribute to resistance to state immunization requirements.
Going forward, the school district will develop a corrective action plan that must be approved by the Board of Education. It may need to explain why it has failed to designate a single person in charge of overseeing and ensuring compliance that the auditor repeatedly recommended and the district said it would do.
The California Department of Public Health warns that, “Schools found to have improperly admitted students that do not meet immunization requirements may be subject to docking of ADA payments for those children.” The auditor has calculated over $300,000 in potentially disallowed reimbursements.
Whether the school district will have to pay those amounts, or any amount, remains to be seen. Looming larger, however, are the potential health and safety risks to students, school employees and their families. While there is debate in some parts of the country about the benefits and risks of some childhood immunizations, that is not the issue in San Francisco. Instead, parents, teachers and community members are faced with “administrative oversight” as the barrier to overcome.