(1.) “A CHILD WHO ATTENDS EDUCATIONAL PROGRAMS WHERE COURSES ARE OFFERED ONLINE ONLY AND THE CHILD IS NOT PHYSICALLY PRESENT AT THE INSTITUTION FOR PARTICIPATION IN ENRICHMENT, ATHLETICS, OR OTHER ACTIVITIES.” Trying to include homeschooled students in vaccine requirements is in direct conflict with statutes in SB2020-163 that clearly detailed in three sections that homeschool students were excluded. This requires a clearly written exclusion for homeschooled students. SB2020-163 dictates that a district can only require vaccines or exemptions from homeschooled students if the student attends a public school for part of the day: “(b) (I) A SCHOOL DISTRICT MAY REQUIRE COMPLIANCE WITH SUBSECTION (1) OF THIS SECTION IF THE STUDENT PARTICIPATING IN A NONPUBLIC HOME-BASED EDUCATIONAL PROGRAM ATTENDS A SCHOOL OF THE SCHOOL DISTRICT FOR A PORTION OF THE SCHOOL DAY;”  SB2020-163 dictates that an online school can only require vaccines or exemptions when students are physically present for enrichment, athletics, or other activities: “O. School - all child care facilities licensed by the Colorado Department of Human Services including: Child care centers, school-age child care centers, preschools, day camps, resident camps, day treatment centers, family child care homes, foster care homes, and head start programs; public, private, or parochial kindergarten, elementary, or secondary schools through grade twelve, or a college or university. SCHOOLS INCLUDE EDUCATIONAL PROGRAMS WHERE COURSES ARE OFFERED ONLINE ONLY BUT WHERE ENROLLED STUDENTS ARE PHYSICALLY PRESENT AT THE INSTITUTION FOR PARTICIPATION IN ENRICHMENT, ATHLETICS, OR OTHER ACTIVITIES.” SB2020-163 dictates that an online student who is NOT physically present for enrichment, athletics, or other activities is an exception to vaccine and exemption requirements. “R. Student - any person enrolled in a Colorado school as defined in section I (O), except: 1. A CHILD WHO ATTENDS EDUCATIONAL PROGRAMS WHERE COURSES ARE OFFERED ONLINE ONLY AND THE CHILD IS NOT PHYSICALLY PRESENT AT THE INSTITUTION FOR PARTICIPATION IN ENRICHMENT, ATHLETICS, OR OTHER ACTIVITIES.”.   (2.) “A CHILD WHO ATTENDS EDUCATIONAL PROGRAMS WHERE COURSES ARE OFFERED ONLINE ONLY AND THE CHILD IS NOT PHYSICALLY PRESENT AT THE INSTITUTION FOR PARTICIPATION IN ENRICHMENT, ATHLETICS, OR OTHER ACTIVITIES.” This is in direct conflict with statutes in SB2020-163 that clearly detailed in three sections that homeschool students were excluded. This requires a clearly written exclusion for homeschooled students. (3.) “FOR MMR, TITERS FOR MEASLES, MUMPS, AND RUBELLA MUST ALL BE POSITIVE. IF ANY SINGLE TITER IS NEGATIVE, THE DEPARTMENT WILL REQUIRE: 1) A CERTIFICATE OF MEDICAL OR NONMEDICAL EXEMPTION FOR THE COMPONENT(S), OR 2) VACCINATION WITH AN MMR VACCINE.” This requirement for college students becomes problematic for older adults who attend college. A separate section I.O.1. states that non-traditional adult students who live off campus and not in residence halls, or use online instruction only, are not included in these requirements for schools. Because this is not clearly re-iterated in the college section IX, colleges and universities have required older adult students to provide vaccine records that the student does not have possession of from childhood. Furthermore, public health workers rarely communicate the right to exemption by titers testing when providing vaccine requirements. Therefore, section IX should clarify the exclusion of vaccine requirements for older adults in college. (4.) “FOR HEPATITIS B, A POSITIVE TITER IS ALLOWABLE ONLY AFTER DOCUMENTATION OF COMPLETION OF AN APPROVED HEPATITIS B VACCINE SERIES.”  Hep B risk groups (per CDC) are drug users who share needles, prostitutes, and men who have sex with men. The vast majority of people do not fit into these categories. Furthermore, a Hepatitis B serologic test can show immunity due to prior infection, which the CDPHE is choosing to ignore or deny.