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Originally published under the title "What's NACCHO got to do with Oregon's vaccine exemption fight?"
NACCHO? It sounds like a bad acronym from an Austin Powers movie. But it is actually one of the most powerful anti-vaccine choice front groups in the country, whose primary funder appears to be the CDC.
It sounds like a bad acronym from an Austin Powers movie.
What/who the heck is NACCHO?
NACCHO is The National Association of County and City Health Officials. If you briefly perused their website, you might be confused into thinking that they were a federal agency of sorts. First off, there's the name. Many people associate "National Association" with something sort of official. The next thing that might throw you off is the way NACCHO describes themselves:
NACCHO's members are the 2700 local health departments across the United States. NACCHO's vision is health, equity, and security for all people in their communities through public health policies and services. NACCHO's mission is to be a leader, partner, catalyst, and voice for local health departments in order to ensure the conditions that promote health and equity, combat disease, and improve the quality and length of all lives.
For the uninitiated, reading NACCHO's self-description might cause you to reach the following conclusions:
- NACCHO is a federal organization
- Its members are all the local health departments
- Somehow, this is a way for all the local health departments to all be connected together, probably there is a rule somewhere that says they should all coordinate themselves on a national basis (and there isn't, the health of citizens is a state-level job, according to the U.S. Constitution)
As you're probably getting used to by now with these articles, NACCHO could not be farther from any of that in reality, so let's look at the details:
1. NACCHO's "membership" revenue numbers don't add up at all
Referring to the conclusions one might draw from the above, it appears that NACCHO is a collective of local health departments. According to NACCHO, there are "over 2700" of them and most people would probably presume these local health departments pay a membership fee to be a part of NACCHO, which they do.
NACCHO has a membership form for local health departments, you can see it right here. If you look at the form, you'll see that local health departments (NACCHO's claim is that they are just a group of local health departments) can join NACCHO, and that their annual membership fees is pro-rated based on how large a population they serve. The most an annual membership could cost any health department would be $4,150 per year, as you can see right here:
Just for fun, we ran the math. 2,700 local health departments. To be conservative, let's say EVERY health department had 3 million or more people in it (which would be impossible because with more than 2,700 health departments as NACCHO members that would mean the U.S. had 8.1 billion people) but let's just see how much money NACCHO could pull in annually from membership dues if that were true:
"Membership Fee of $4,150 x 2,700 local health departments= $11,200,000"
Here's the problem. NACCHO breaks out their revenue from membership dues on their 990 form. Are you ready for this? Here's what NACCHO actually made in membership revenues in 2013:
If you are saying, at this point, "so what"? You're right. We haven't proven anything. In fact, the only thing you know about NACCHO so far is that:
- They claim to be a collective of 2,700 local health departments. (In fact, it's fair to say this is the primary way they define themselves.)
- From their members they receive just over a half million dollars a year in membership dues, according to their 2013 990 form filed with the IRS.
Here's the problem NACCHO makes $25 MILLION a year in revenues:
$25 million a year? That means membership dues—which NACCHO implies defines who they are—are responsible for approximately 2% of their annual revenues.
2. NACCHO makes all their money from government and private grants
With membership dues of roughly $500,000 and revenues of $25 million, the story on NACCHO is $24.5 million short of an explanation. Luckily, their 990 has to break out sources of revenue one step further, which is how we learn the following:
NACCHO is making the majority of their annual revenue from two sources: government grants ($19.3 million) and other grants ($3.6 million).
Government grants? What kind of government grants? Who, aside from a local health department, wants to contribute to an organization that represents local health departments? Remember, NACCHO's mission is very clear:
"NACCHO's mission is to be a leader, partner, catalyst, and voice for local health departments"
Unfortunately, NACCHO's Form 990 doesn't break out exactly where their Government grants come from, but this document gives you a pretty good idea:
NACCHO spells out who their partners (funders) are on their website right here. CDC is listed. So is the Immunization Action Coalition. And, a myriad of other "private nonprofts" that focus on public health.
Can we draw any conclusions from this information? Sure we can:
NACCHO gets most of their money from government grants. CDC appears to be a primary funding source.
What does any of this have to do with Oregon? As the readers of this series know, Oregon is currently experiencing an intense fight over Senate Bill 442, a bill sponsored by State Senator Elizabeth Steiner Hayward that would remove both philosophical and religious exemptions from Oregon, effectively making vaccinations in Oregon mandatory for a parent who wants to send their child to any kind of school.
NACCHO and the Oregon Legislature
This article was spurred by repeated reports from members of the Oregon Legislature that they were being heavily lobbied by a group called NACCHO about Senate Bill 442. In general, NACCHO was characterized as a primary advocate of Senate Bill 442. This would make sense, since in July 2011 NACCHO issued a very clear policy statement that the time had come for states to eliminate personal belief exemptions:
the National Association of County and City Health Officials (NACCHO) urges that personal belief exemptions be removed from state immunization laws and regulations.
NACCHO acknowledges that there are states that may not be in a position to eliminate personal belief exemptions immediately. States that easily permit personal belief exemptions to immunizations have significantly higher rates of exemption than states that have more complex procedures. These states should begin a process to limit the availability of personal belief exemptions to the greatest degree possible. An initial step might be to review the process of applying for and receiving exemptions: the more educational and demanding the process, the lower will be the rate of exemptions. There should be more involved in the application process than simply signing a form.
This isn't the first policy statement from NACCHO. A quick compilation of statements shows where the nonprofit group who get all their money from government grants is focused:
Do NACCHO's policies share a common theme? Clearly:
- Mandatory vaccines
- National registries of vaccination status
- More vaccines
- All vaccines
Cradle to Grave
But, perhaps NACCHO's future goals should be of most concern to Oregonians. In July 2013, NACCHO's Board approved this new policy statement, titled "An Immunization Program for all Stages of Life":
The National Association of County and City Health Officials (NACCHO) urges the federal government to support the creation of a comprehensive national immunization program that addresses all stages of life (cradle to grave) with the intention of achieving the Healthy People 2020 immunization goals and standards. Such a program will help protect our nation's population from vaccine-preventable diseases by increasing rates of childhood, adolescent, and adult immunization coverage.
Cradle to grave?
Yes, that's what NACCHO said. They go on to write:
A function of many state and local health departments is to collect vaccination data and maintain immunization registries. These registries are often used to help ensure children and adolescents have up-to-date immunizations. Low levels of vaccine coverage among adults underscores the need to expand these systems to include adults and for providers to develop systems to minimize missed opportunities.
Immunization registries for adults?
Oregonians, it's time to wake up. Let's put SB442 in proper context: its just another step in the plan of comprehensive mandatory immunizations for everyone, including ADULTS.
"Cradle to grave," as NACCHO says.
Is it really that hard to imagine what their policy statement for adult vaccinations will say in a few years?
If you support SB442, you also need to support getting up to date on your adult vaccines—the CDC recommends 72 vaccinations between the ages of 19 and 65. Are you going to get your 72 shots?
Is NACCHO breaking the law?
We're not attorneys, but we are very troubled by this document which we found on NACCHO's website that deals with prohibitions of lobbying on the part of organizations that receive grants from the CDC, like NACCHO. The language is pretty unambiguous:
"Except in certain cases of state and local government communication, as part of their normal and recognized executive-legislative relationships, as discussed above, grantees [like NACCHO] are restricted from using federal funds to attempt to influence deliberations or actions by Federal, state, or local legislative or executive branches. This includes communications to a legislator or executive official that refer to and reflect a view on specific measure (legislative or executive)."
We're just parents. We haven't sat in the room during the meetings between our elected representatives here in Oregon and NACCHO, but we'd sure ask our elected representatives to take a close look at these prohibitions and compare those to NACCHO's efforts on behalf of SB442.
So, what have we learned?
- According to Oregon legislative members, NACCHO is heavily lobbying in support of SB442, which appears to violate CDC grantor rules, but we're not lawyers.
- NACCHO is not a member-funded organization as their self-characterization implies (less than 2% of revenues from membership dues). NACCHO is an independent nonprofit entity that relies almost exclusively on government grants to operate. CDC is certainly one of the granting organization and given the scale of interaction and partnership between CDC and NACCHO, it's likely CDC is one of the largest grantors. If true, NACCHO may be better described as a "captive nonprofit" which others might call a "front group"
- In July 2011, NACCHO issued a policy statement encouraging states to eliminate personal belief exemptions. If that wasn't a possibility, NACCHO at least encouraged states to make exemptions harder to get by making the process more cumbersome.
- In June 2013, 24 months later, the Oregon Legislature passed Senate Bill 132, which made personal belief exemptions harder to get. Their approach perfectly matched the recommendations of NACCHO from July 2011.
- Now, two session later, with Senate Bill 442, there is a movement to eliminate all non-medical vaccinations, and NACCHO is heavily involved.
- The long-term plan for NACCHO is adult immunization—"cradle to grave" as they say. Anyone who doesn't believe a push for mandatory adult vaccinations is likely somewhere in the near future is not paying attention.
If you support Senate Bill 442, you are supporting a path to mandatory adult vaccinations, plain and simple, and the hand of the CDC in all of this is very hard to miss.
Who's behind Oregon Senate Bill 442? We think the answer is fairly obvious.
This article was written by several well-meaning Oregonians who are big fans of medical freedom and informed consent who apparently have nothing better to do than crunch numbers. We have nothing to gain or lose financially from the passage of this bill. We have proudly joined a movement of a few thousand Oregonains fighting this legislation, the organizing website can be found here: www.NoOnSB442.com. We have actually written four articles on this topic, in chronological order they include:
Part 2: Who cried wolf in Oregon
Part 4: Exemption-gate in Oregon?