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The Delta Variant & FDA-Approved Vaccine May Mean More Mandates

oswaldcompanies August 24, 2021
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As the summer winds down, several new developments on the COVID-19 front are having a massive impact on how organizations across all industries approach vaccination policies. With the surging Delta variant, news of at least one additional variant and recent FDA approval of the Pfizer/BioNTech COVID-19 vaccine (with more approvals to come) at the forefront of all businesses’ minds, the decision of whether or not to mandate vaccinations looms.

In an update from our partner company, RCM&D, released back in May, the following write-up provides guidance steered at policies that mandate vaccinations or frequent testing. Additionally, a vaccination or frequent testing mandate will make tracking your immunization efforts more critical than ever.

Human Resources Policies

With the FDA approval of the Pfizer/BioNTech COVID-19 vaccine, many organizations will be more inclined to mandate the COVID-19 vaccine as part of their corporate policy. In fact, many large organizations such as Amtrak, Delta Airlines, and more have already mandated vaccinations or frequent testing. This sentiment is compounded by the continuous spread of the COVID-19 Delta variant, which is more prevalent among unvaccinated individuals than vaccinated individuals. Whether your organization mandates vaccinations or not, effective human resource policies are a critical first step to establishing an effective vaccination policy.

According to a recent write-up from The Society of Human Resource Management (SHRM)— should your organization decide to move towards a mandated vaccine or frequent testing policy— HR should be prepared to clearly communicate the rationale behind why a mandate is taking place. The policy should also communicate any consequences (such as frequent testing and mask-wearing requirements) for employees who choose not to be vaccinated. Consequences of refusal to meet vaccination or testing/safety requirements should be adequately communicated.

While some employees may opt out of vaccinations, it is critically important that leadership and HR professionals treat all employees equally. One best practice highlighted by SHRM is to supply accommodation request forms to help employees and HR staff identify relevant information that can help determine if the request for an exemption is reasonable. Again, any alternative requirements such as mandatory mask usage or frequent testing must be clearly outlined.

Example Procedures for Vaccine Mandates

There are several things to consider when establishing a mandated vaccination or frequent testing policy. SHRM has developed several sample forms which include a good baseline for important procedural standards to consider.

These procedural examples include:

  • Inform employees of what vaccines are covered under the mandatory policy and the timeframe they should be administered.
  • The COVID-19 vaccine is free for all US citizens, as authorized by the federal government. For all other vaccination efforts (like annual flu shots), employers should provide free, in-house vaccinations in the event of a mandate. Vaccinations should be run through an employee’s health insurance when performed offsite and submitted for reimbursement when applicable.
  • Provide paid time off to receive vaccinations. Management should work with employees to schedule an appropriate time to be vaccinated.
  • Require proof of vaccination from employees before a required deadline. Proof of vaccination or an approved and reasonable accommodation should be required for exemption from these policies.

If an employee has valid religious or medical needs, an exemption from these policies can be requested through a completed “Request for Accommodation” form. This form allows the HR department to begin the interactive accommodation process as soon as vaccine deadlines are announced. Accommodations will only be granted when they do not cause the organization undue hardship or pose a direct threat to the health and safety of others.

Tracking Your Vaccination Effort

If your organization mandates vaccinations, having a comprehensive system for monitoring vaccination status is critical to risk management efforts as well as the workers’ compensation program. It is important to note that vaccination records should be maintained in compliance with HIPAA regulations and not as part of the individual’s general employment records. Almost as important as tracking vaccinations is the need to track the testing dates and results of those employees who opt-out of the vaccination and are subject to frequent testing policies.

Data that organizations should track during their vaccination efforts includes:

  • Number and list of the population vaccinated or opting out.
  • For those opting out, it is important to be able to track testing dates and results in accordance with your frequent testing policy.
  • Percentage of the population vaccinated by state, location, and department.
  • Paid leave provided to employee populations to obtain vaccination.
  • Upcoming and missed booster shots by manufacturer – especially as boosters for COVID-19 become available for more individuals.
  • Adverse reactions and related workers’ compensation claim number (for employee vaccinations).

Tracking Tools Can Help

The need to thoroughly track vaccine data can quickly become daunting for leadership and HR staff. To ease the burden on staff and maintain accurate, HIPAA-compliant records, vaccine-tracking services may be a solution to consider.

A new vaccination tracking solution from SISCO can help businesses track their vaccination efforts with the backing of a team of experts and a simplified, intuitive dashboard. Using a tracking program allows your organization to turn its data into actionable insights. Instead of filtering through multiple spreadsheets, you can quickly drill down to view your progress by division, facility, location or any custom field unique to your organization. This enables you to implement new programs and educational efforts as well as quickly pull records for any necessary reporting requirements (whether mandated or voluntary).

Additional Questions?

An effective vaccination effort includes well-thought-out policies, educational programs, consideration of targeted incentives and most importantly, a mechanism to measure the success of your program.  Fill out of the form below to talk to a trusted advisor today for more on vaccination mandates and how our vaccine-tracking tool can help your organization.

This article also appeared on rcmd.com.


Note: This communication is for informational purposes only. Although every reasonable effort is made to present current and accurate information, Oswald makes no guarantees of any kind and cannot be held liable for any outdated or incorrect information. View our communications policy.