CONEMAUGH HEALTH SYSTEM EMPLOYEE HEALTH POLICY MANUAL
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1 CONEMAUGH HEALTH SYSTEM EMPLOYEE HEALTH POLICY MANUAL TITLE: INFLUENZA IMMUNIZATION POLICY STATEMENT OF POLICY: The Conemaugh Health System (CHS) is committed to providing a safe and healing environment for our patients and protect our employees, their families, and our community. Effective July 1, 2014, all individuals working at CHS (employees, members of the medical staff, physician assistants, advance practice nurses, residents, students/trainees, instructors, contract personnel, and volunteers are required to be immunized against influenza each flu season unless a specific exemption is requested and approved in accordance with this policy prior to a date to be determined and announced by CHS on an annual basis. Board members and community committee members that will be on site during the influenza season (Oct 1 to April 1) will be offered and encouraged to receive the influenza vaccine at no cost in an effort to further protect patients, visitors, and staff. Refer to the specific policies for vendors/contracted employees and medical staff. IMPLEMENTATION: 1) All staff working in the CHS must be immunized against influenza each year. This includes ALL personnel described above including those students rotating here for one day or more. Students who job shadow for only one day between October 1 to April 1 do not need to show proof of vaccination. If someone is to job shadow for more than one day, then vaccination will be required. 2) Influenza vaccine is available free of charge. The vaccination program is coordinated through the Employee Health Office (EHO). Dates of the influenza program will be determined by the Employee Health Office and Epidemiology, Prevention and Infection Control on an annual basis. 3) Vaccination compliance will be monitored through the EHO. 4) Those individuals who are vaccinated through services other than the CHS (private physician office, public clinics, drug stores, etc.) must provide proof of immunization to the Employee Health Office. Proof of immunization may include a physician/extender note, a receipt, or copy of consent. 5) Employees on a leave of absence or FMLA when the flu season starts are encouraged to receive the flu vaccine prior to returning to work; however if the employee has not received the flu vaccine, they should contact Employee Health to make arrangements to receive the vaccine on the FIRST DAY of returning to work. If the employee returns to work on a weekend or holiday the employee needs to make arrangements to be immunized prior to the start of the shift.
2 6) Exemptions: For new hires and current employees, any exemption because of medical contraindications or religious reasons must be submitted to Employee Health by September 1 st. a) An individual requesting medical exemption because of a medical contraindication must complete a Request for Medical Exemption from Influenza Vaccine Form and have it signed by primary care physician/provider. [Appendix A] i) Standard criteria for medical exemption will be established based upon recommendations from the Centers for Disease Control and Prevention (CDC). Medical contraindications include: Severe allergic reactions to eggs History of previous severe allergic reaction to influenza vaccine or a component of the vaccine. History of Guillain-Barre syndrome within 6 weeks of receiving a previous dose of influenza vaccine. ii) Each request for medical exemption, regardless of the reason, will be evaluated individually by the Influenza Exemption Evaluation Team. This team will include: o Medical Director for the Employee Health Office (EHO) o Medical Director of Epidemiology, Prevention, and Infection Control (EPIC) o Associate Medical Director of Professional Affairs o Medical Staff President o Chief Medical Officer o Director of Human Resources o Director of Quality Excellence o Spiritual Care Coordinator o Conemaugh Physician Group (CPG) Director of Clinical Services o Memorial Medical Center EHO Nurse o Miners EHO Nurse o Meyersdale EHO Nurse iii) If medical exemption is granted, the individual will be notified in writing (Appendix C) by September 15 th. iv) For employees who are hired after the September 1 st exemption application deadline, exemption notification will occur in writing within five business days after presenting a request for exemption to the EHO. v) If exemption request is denied, the individual will be required to be immunized per the policy. vi) For those with an allergy to eggs, the availability of Flublok will be reviewed, ordered, and administered to the employee on a case-by-case basis. Flublok does not use the influenza virus or eggs in its production. vii) If exemption is granted for a permanent condition (allergy or history of Guillain- Barre after a previous influenza vaccine) the exemption does not need to be requested each year unless vaccine technology would change to eliminate issues regarding allergies. b) Individuals requesting a religious accommodation must complete a Request for Religious Exemption from Influenza Vaccination form (Appendix B) and submit it to
3 the EHO by September 1 st. Applicants are encouraged to have their clergy sign this form, but it is not required. o The religious exemption will also be evaluated by the Influenza Exemption Evaluation Team. o Those employees who submit for a religious exemption need to resubmit their exemption annually. 7) The annual timeline for influenza vaccination will be as follows: (specific dates will be determined by the Employee Health Office annually based on vaccine availability, consultation with the Chairman of the EPIC committee, Director of Quality Excellence, Director of Human Resources and Administration) Mid September to early December influenza vaccination available and administered to all staff. Mid November managers will be notified of staff non-compliant with the vaccination. The manager will notify the non-compliant staff members verbally or in writing that they must file for an exemption or be vaccinated by December 1 st. December 1 st : If an individual is not vaccinated or granted an exemption by this date they will be subject to further corrective action up to termination. December 1 st to March 1 st vaccination will be available for new hires, individuals who return from LOA, or other special cases. 8) Refer to the medical staff privilege by-laws and Influenza Immunization Policy for Medical Staff regarding mandatory influenza vaccination for physicians/extenders working at a Conemaugh Health System entity. 9) Influenza season typically occurs sometime between November and March. When influenza has been identified in the community (based on reporting from the Department of Health and determination by the Chief Medical Officer in consultation with the EHO, Epidemiology, Infection Prevention and Control and Human Resources), individuals granted an exemption will be requested to take extra precautions during the outbreak period: o May wish to take PTO or unpaid time off during the epidemic period o May wish to mask during the epidemic period 10) During the influenza season all employees will be encouraged to be vigilant against the flu. a) All employees will be responsible for monitoring their health status and reporting to work only when they are not in a status that would put others at risk of contracting the flu. i) Influenza symptoms may include: Fever (usually high) Headache Tiredness (can be extreme) Cough Sore throat Runny or stuffy nose Body aches ii) If an employee has a flu like illness, he/she should stay home for at least 24 hours after his/her fever is gone. (Fever should be gone without the use of a fever-reducing medicine.) b) All employees will be responsible for following appropriate infection prevention and control standards to prevent risk to others and themselves. This includes, but is not
4 limited to, frequent hand washing, covering coughs and sneezing, disinfecting equipment and work stations, and not reporting to work when ill. 11) In the event of an influenza vaccination shortage, the situation will be evaluated by the Chief Medical Officer at the corporate level in collaboration with the EHO, Infection Control, Human Resources, Pharmacy, and Administration. Influenza vaccine will be offered to personnel covered by this policy based on job function and risk of exposure to influenza. Priority will be given to those who provide direct hands-on patient care with prolonged faceto-face contact with patients, care for patients at high risk for complications from influenza and/or have highest risk of exposure to patients with influenza, as well as to personnel who are at high risk for complications from influenza. CMS Reporting Requirements: The Centers for Medicare & Medicaid Services (CMS) requires reporting on three categories of health care personnel (HCP): o employees (regardless of patient contact) on facility payroll o licensed independent practitioners (LIP) : non-employee physicians, advanced practice nurses, and physician assistants; this category includes Conemaugh Physician Group (CPG) providers o adult students, trainees and volunteers (ASTV) aged 18 or older. Although not required by CMS, CHS will exercise the option to track influenza vaccination coverage among contract personnel because it is encouraged by The Joint Commission (TJC). The following types of facilities are required to report HCP influenza vaccination data under their participation in their respective CMS quality reporting programs: o Acute care hospitals for both inpatient and outpatient units/departments that share the same CMS Certification Number (CCN) as the hospital e.g. Memorial Medical Center (MMC) and Miner s Medical Center (MiMC) for the IQR and OQR programs o Inpatient rehabilitation facilities (IRF) e.g. Crichton o Inpatient psychiatric facilities (IPF) e.g. Geropsychiatric Behavioral Health Unit Facilities are required to submit summary data on influenza vaccination of HCP via the Center for Disease Control and Prevention s (CDC) National Healthcare Safety Network (NHSN). HCP influenza vaccination summary data submitted by facilities will be shared by the CDC with CMS. The CDC will provide a hospital-specific HCP influenza vaccination percent for each reporting facility on CMS Hospital Compare website. Although CMS only requires participation from certain types of facilities, the Pennsylvania Department of Health (PA DOH) is requesting this information from all hospitals required to report under Act 52. Rates from each institution will be displayed publicly in the Department s Healthcare Associated Infection (HAI) Annual Report. Facilities that elect not to submit their data will be noted in the HAI Annual Report. Meyersdale Medical Center (MyMC) is required under Act 52 to report their vaccination data into NHSN following the same methodology.
5 NHSN Methodology: For CMS and PA DOH reporting compliance, data will be entered into the National Healthcare Safety Network (NHSN) Healthcare Personnel Influenza Vaccination Module Health Care Personnel Influenza Vaccination Summary. MMC, MiMC, MyMC and Crichton are responsible for data entry into NHSN as separate NHSN facilities. MMC will report Geropsych s data. NHSN definitions and reporting requirements are followed for numerator and denominator data and for calculation of overall vaccination compliance percentages. The overall vaccination compliance percentages is calculated two ways with and without other contracted personnel (OCP). At this time, reporting to NHSN for this category is optional; however, including OCP in vaccination compliance percentages is strongly encouraged by The Joint Commission (TJC). Each facility is responsible for calculation of vaccination compliance percentages for their facility. HCP Vaccination Compliance Percentage (excluding OCP) # Employees + # LIP + #ASTV vaccinated onsite or elsewhere # Employees + # LIP + #ASTV working in the required time period HCP Vaccination Compliance Percentage (including OCP) # Employees + # LIP + #ASTV + # OCP vaccinated onsite or elsewhere # Employees + # LIP + #ASTV working in the required time period RESPONSIBILITY: Employee Health and Human Resources is responsible for implementation of this policy. Tracking of CHS health care personnel (HCP) vaccination compliance rates, including medical and religious exemptions, will be managed by the MMC Employee Health Office (EHO). RELATED POLICIES/PROCEDURES/GUIDELINES AND FORMS: Conemaugh Health System Request for MEDICAL Exemption from Influenza Vaccination Conemaugh Health System Request for RELIGIOUS Exemption from Influenza Vaccination Conemaugh Health System Request for Exemption from Influenza Vaccination Committee Review Influenza Vaccination Consent Form
6 ORIGINAL POLICY DATED: 7/1/14 REVISED: 7/23/15 NEXT REVIEW DATE: 7/1/17 SIGNATURE: Steven E. Tucker President, Conemaugh Memorial Medical Center Hospital Division CEO Dr. Celine Gisbert Medical Director Employee Health Actual signatures on file in Employee Health
7 Appendix A Conemaugh Health System Request for MEDICAL Exemption from Influenza Vaccination CHS Staff Member Name Date of Birth Employee ID Number or Medical Staff Area of Specialty Employee Department Contact Phone Number Primary Care Provider name PCP Contact information (phone/ ) Influenza Vaccination Requirement On July 1, 2014 the Conemaugh Health System, as a safety initiative, began requiring influenza vaccination, similar to other required vaccinations such as measles and varicella. For decades, influenza vaccination has been recommended for healthcare workers, and has been shown in study settings to be effective in protecting patients and staff. Influenza vaccination is also recommended in pregnancy by the Centers for Disease Control and Prevention and the American College of Obstetricians and Gynecologists to protect pregnant women who are at increased risk of severe disease and to protect the baby after it is born. The CDC also strongly endorses mandatory influenza immunization for all healthcare workers. To Be Completed by Primary Care Provider: Your patient is requesting to be exempt from this vaccination. Medical exemption from influenza vaccination is allowed for recognized contraindications (CDC MMWR Early Release 2010; Vol. 59. Available online: Please complete the form below to request medical exemption for your patient. Should you have any questions, please call (814) My patient should not be vaccinated against influenza for the following reason: Recognized contraindication to influenza vaccination (please mark which one) Severe reaction to eggs (defined as developing hives, swelling of lips or tongue, difficulty breathing). The amount of egg protein in influenza vaccines is extremely small. People who can tolerate eating foods prepared with eggs, such as baked goods, can generally tolerate the influenza vaccine. o For those with an allergy to eggs, the availability of Flublok will be evaluated, ordered, and administered on a case-by-case basis. Flublok does not use the influenza virus or eggs in its production. History of previous severe allergic reaction to the influenza vaccine or component of the vaccine. (does not include sore arm, local reaction, or subsequent upper respiratory tract infection). History of Guillan-Barre syndrome within 6 weeks of receiving previous vaccine. (CDC Recommendation) Hx of Guillan-Barre syndrome (not related to vaccination) Other please describe _ PCP Signature Date: Applicant cannot sign exemption request. Additional comments may be provided on the back of this document.
8 Appendix B Conemaugh Health System Request for RELIGIOUS Exemption from Influenza Vaccination CHS Staff Member Name Date of Birth Employee ID Number or Medical Staff Area of Specialty Employee Department Contact Phone Number Influenza Vaccination Requirement On July 1, 2014 the Conemaugh Health System, as a safety initiative, began requiring influenza vaccination, similar to other required vaccinations such as measles and varicella. For decades, influenza vaccination has been recommended for healthcare workers, and has been shown in study settings to be effective in protecting patients and staff. Influenza vaccination is also recommended in pregnancy by the Centers for Disease Control and Prevention and the American College of Obstetricians and Gynecologists to protect pregnant women who are at increased risk of severe disease and to protect the baby after it is born. The CDC also strongly endorses mandatory influenza immunization for all healthcare workers. Request for Influenza Immunization Exemption for Religious Reasons I request that I be exempted from Conemaugh Health System s influenza vaccination requirement because my sincerely held religious beliefs, practices, or observances prevent me from receiving the influenza vaccine. Please describe below your sincerely held religious belief, practice, or observance that prevents you from receiving the influenza vaccine and attach any literature or other written materials that support you request for religious exemption: CHS Staff Member signature: Date Clergy Signature (optional):
9 Appendix C Conemaugh Health System Request for Exemption from Influenza Vaccination MEDICAL or RELIGIOUS Committee Review Employee Name Date of Birth Employee ID Number Employee Phone number/department EXEMPTION HAS BEEN Granted you do not need to receive the vaccination due to medical reasons Granted you do not need to receive the vaccination due to religious reasons Declined o Failure to be immunized by / 4 PM will result in corrective action. You will need to receive the Flublok vaccine due to your egg allergy Signature of Committee Certified letter sent to the employee on :
10 Influenza Vaccination 2015/16 Information about person to receive vaccine please print Name: Last First Middle initial Date of birth Department: Extension Check one below: MMC Main Campus Employee Physician or Extender (PA/NP) Volunteer MMC Lee Campus Employee CPG Employee Student MMC Westwood Site Miners Employee Contracted Employee MMC East Hills Site Meyersdale Employee Other: I have read information on the vaccine information sheet about the influenza vaccine and I have asked questions as needed which were answered to my satisfaction. I believe I understand the benefits & risks. The influenza vaccine is safe in pregnancy. Have you ever had a serious reaction to eggs? Yes No Have you ever had a serious reaction to the influenza vaccine? Yes No Have you ever had Guillain Barre syndrome? Yes No Are you feeling ill today with a fever or other symptoms? Yes No If you answered yes to any of the questions you will not be given an immunization today. Signature Date Vaccine given Fluvirin Afluria Fluzone Flublok FluMist Date vaccinated 0.5mL IM Site of injection Right deltoid Left deltoid Manufacturer and Lot Number Expiration date Signature of clinician administering vaccine Vaccine information sheet provided to employee
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