Human Resources Policy/Procedure Title: Influenza Vaccination Policy Effective/Revised Date: July 15, 2017 PURPOSE: Influenza vaccination is important for the protection of our patients and their families, the public, and Mercy co-workers and physicians. Mercy has developed this Influenza Vaccination Policy ( Policy ) in response to the continued risks of seasonal and pandemic flu in our healthcare setting. This Policy is intended to maximize vaccination rates against influenza among Mercy personnel and to protect patients, co-workers, and the broader community from influenza infection. Mercy requires that all co-workers, physicians (integrated and independent), credentialed medical staff (as well as their employed or sponsored advanced practice professionals and clinical assistants), students, residents, interns, fellows, volunteers, clergy, contracted personnel and vendors working in Mercy facilities be immunized against influenza on an annual basis. Mercy will require documentation and/or assurances of influenza vaccination regarding non-mercy-employed personnel working at our facilities. For the purposes of this Policy, a reference to influenza vaccination or flu vaccine refers to the influenza shot and any other acceptable alternative available during the flu season. POLICY: Mercy takes reasonable and lawful measures to protect its patients, visitors, community, physicians and co-workers from the transmission of communicable illnesses or disease. This Policy outlines the procedures that will guide Mercy in its efforts to minimize the spread of the influenza virus. This Policy is based on practices and recommendations from various organizations, including but not limited to: Centers for Disease Control, The Joint Commission, Association for Professionals in Infection Control, and state and local health departments. In addition to complying with this Policy, all Health Care Personnel are responsible for performing appropriate infection control standards and are required to comply with policies on Infectious/Communicable Diseases, Hand Hygiene, Respiratory Etiquette, Personal Protective Equipment, etc. PROCEDURE: Annual Influenza Vaccination 1. Influenza vaccinations will be provided to all Mercy personnel according to published recommendations from the CDC, AAAAI, ACIP, and the local Health Department, with consideration given to the availability of vaccine. Compliance with annual mandatory influenza vaccination will be required no later than November 15. 2. Under the direction of the hospital and clinic leadership and a local team of physicians and leaders, Mercy will determine the onset and termination of any flu season and/or epidemic that falls outside Mercy s established flu/masking season (November 15 to March 31) based on information from the local Health Department. 3. Vaccination timeframes may vary according to vaccine availability and local Health Department recommendations. If there is a shortage or delay of influenza vaccine supply that affects the supply of influenza vaccine for co-workers, Mercy will develop a contingency plan. This plan 1 P a g e
will include vaccine prioritization and distribution based on the influenza vaccine supply shortage faced and recommendations from the CDC and the local Health Department(s), and a potential adjustment to the November 15 vaccination deadline. 4. In the event the influenza vaccine supply is limited, Mercy will offer the vaccine using a tiered process, beginning with individuals most at risk for occupational acquisition and patient exposure, and working through each level of priority based on job function and risk of exposure until the supply is exhausted. The tiers will be developed by a task force comprised of representatives from Employee/Corporate Health, Infection Prevention, Infectious Disease and Administration. 5. In the event of an epidemic, Infection Prevention, Employee/Corporate Health and the Emergency Management team will communicate with the local Health Department on vaccine distribution, administration and reporting requirements. Responsibilities 1. As a condition of employment, maintenance of medical staff privileges or access to patient care or clinical care areas, Mercy requires all Mercy co-workers, physicians (integrated and independent), credentialed medical staff, and other personnel working in Mercy facilities to receive the annual influenza vaccine by November 15 or possess an approved medical or religious exemption. 2. Annually, co-workers, physicians and other personnel covered by this Policy must do one of the following: Receive the influenza vaccine(s) from Mercy Employee/Corporate Health by November 15. Provide Mercy proof of vaccination to Employee/Corporate Health by November 15. Proof of vaccination must include a copy of documentation indicating the vaccine was received by November 15. Comply with the designated procedure for obtaining a medical or religious exemption by November 1, as described in this Policy. If the exemption request is not approved, the individual must receive the influenza vaccination by November 15. 3. All candidates who accept a position of employment with Mercy, as a condition of employment, are required to receive the influenza vaccine, agree to receive the influenza vaccine (if hired outside flu season), provide proof of current vaccination status, or obtain a medical or religious exemption prior to or on the first day their employment. Failure to do so will result in rescission of the offer of employment. Exemptions Mercy will grant exemptions to the annual influenza vaccination for approved medical reasons or sincerely held religious beliefs. Unless granted a permanent medical exemption, exemption documentation cannot carry over from a previous flu season. Exemption requests must be submitted by November 1. Individuals can appeal and request reconsideration of denied exemption requests from the Review Committee. The Review Committee will respond back to the co-worker or integrated physician as soon as practicable. Unless the individual has developed a new condition since November 1, exemption requests and appeals will not be accepted after November 1. 2 P a g e
Medical Exemption The influenza vaccine is safe, and several alternatives are now available for those who have had allergic or other reactions in the past. Nevertheless, exemptions to the mandatory annual influenza vaccination may be granted for certain medical contraindications. Persons requesting an exemption because of medical contraindications must obtain a medical certification (form is attached to this Policy) from their health care provider and electronically complete and submit a Medical Exemption Request Form at: https://mercysecure.formstack.com/forms/request_for_medical_exemption_from_seasonal_influenza_vaccination_2017. The individual requesting the medical exemption will be notified as to whether his/her request for medical exemption has been granted. If a medical exemption request is denied, the individual will be required to be vaccinated pursuant to this Policy. Generally, individuals who receive an approved medical exemption must resubmit a request for exemption annually. Individuals who have medical contraindications to the influenza vaccine, which are permanent and unlikely to have a satisfactory solution in the future, may be granted a permanent exemption. Mercy s Chief Quality Officer will review the medical exemption requests and determine whether to grant a permanent exemption to eliminate the requirement of obtaining a release each year. Religious Exemption Exemptions to mandatory annual influenza vaccination may also be granted if vaccination conflicts with the tenets of a sincerely held religious belief. Persons requesting an exemption because of sincerely held religious beliefs must obtain a certification (form is attached to this Policy) from their religious leader (or other person who can attest the individual s religious beliefs are sincerely held) and electronically complete and submit a Religious Exemption Request Form at: https://mercysecure.formstack.com/forms/request_for_religious_exemption_from_seasonal_influenza_vaccination_2017. The individual requesting the religious exemption will be notified as to whether his/her request for religious exemption has been granted. If a religious exemption request is denied, the individual will be required to be immunized pursuant to this Policy. Individuals who do not receive the influenza vaccination due to an approved medical or religious exemption must wear a surgical mask during the influenza season when present at Mercy facilities. Masking will begin on November 15 (unless there is an earlier flu season indicated by prevalence in the community) and continue through March 31 (unless data from the community indicates a later flu season). Mercy will inform co-workers of the beginning and end date(s) of the masking requirement to the extent such dates fall outside the normal masking season. An annual influenza vaccination or approved medical or religious exemption is required by Mercy as a condition of employment. Failure to comply with the influenza vaccination and/or masking requirements will lead to corrective action as outlined below: Co-workers and integrated physicians who are not vaccinated or granted an exemption by the November 15 deadline will be terminated. 3 P a g e
Mercy will rescind conditional employment offers from all candidates who are not granted an exemption and who refuse to be vaccinated. Members of the medical staff who are not employed by Mercy and who do not comply with the flu vaccine requirement will have their staff privileges suspended until they provide proof of immunization. Volunteers, vendors, trainees, students, residents or fellows, or temporary workers who fail to comply with Mercy s Influenza Vaccination Policy will not be permitted on Mercy premises. Co-workers and physicians who are not immunized, due to a documented medical or religious exemption, and who fail to adhere to the masking requirements will receive corrective action, up to and including termination. Leaders must ensure their direct reports either receive the vaccination or comply with the masking requirement. Masks are to be kept clean and free from personal markings, artwork, etc. Department/Clinic leaders are responsible for ensuring compliance with this Policy within their individual departments/clinics. This Policy is essential to helping our community reduce the spread of influenza, especially to those most at risk. As co-workers/physicians, our values place us in a position of responsibility to protect those we serve and work with, to the best of our ability. THIS IS AN INSTITUTIONAL POLICY AND MAY NOT BE REVISED, CHANGED OR AMENDED DEPARTMENTALLY. THIS POLICY SUPERSEDES AND REPLACES ANY AND ALL PRIOR INFLUENZA VACCINATION POLICIES AND INCONSISTENT VERBAL OR WRITTEN POLICY STATEMENTS. APPROVALS: Legal review by: Nathan Harris (Labor and Employment Counsel) Final Review and Approval by: Cynthia Mercer (SVP- Chief Administrative Officer) 4 P a g e
Request for Medical Exemption from Seasonal Influenza Vaccination HEALTH CARE PROVIDER CERTIFICATION To be completed by the requestor s personal health care provider. Patient Name: Date of Birth: As a safety initiative, Mercy requires its co-workers and physicians to receive an annual influenza vaccine. Your patient is requesting a medical exemption from the influenza vaccination. Medical exemptions are granted only for recognized contraindications. The CDC recognizes that there are no absolute contraindications for receiving the influenza vaccine. A history of anaphylaxis with influenza vaccination administration or onset of Guillan-Barre within 90 days of influenza injection are the only relative contraindications. The American Academy of Allergy & Immunology has recommendations for administering the influenza vaccine in those with a history of anaphylaxis. Anaphylaxis after influenza vaccination is rare and a previous history is relative, not absolute. Medical exemption decisions will be made based on the recommendations from the CDC, AAAAI and ACIP. Please clarify your patient s contraindication(s) to the influenza vaccine: Severe Egg Allergy Description of Reaction: Date of Reaction: Previous reaction to influenza vaccine (e.g. hives, difficulty breathing, swelling of tongue or lips) The above does not include sensitivity to the vaccine such as an upset stomach or mild to moderate local reactions such as soreness, redness, itching, or swelling at the injection site. The above does not include subsequent upper respiratory infection or low-grade or moderate fever following a prior dose of the vaccine. Description of Reaction: Date of Reaction: History of Guillain Barré Syndrome Date Patient had GBS: Other Description of Reaction: Date: 1
I CERTIFY that my patient has the contraindication as identified above and request that he/she be considered for a medical exemption from the influenza vaccination. Physician Name (PRINT): Address: Phone: Physician Signature: *** Important Warning: The Genetic Information Nondiscrimination Act of 2008 (GINA) prohibits employers and other entities covered by GINA Title II from requesting or requiring genetic information of an individual or family member of the individual, except as specifically allowed by this law. To comply with this law, we are asking that you not provide any genetic information when responding to this request for medical information. "Genetic information" as defined by GINA, includes the results of an individual's or family member's genetic tests, the fact that an individual or an individual's family member sought or received genetic services, and genetic information of a fetus carried by an individual or an individual's family member or an embryo lawfully held by an individual or family member receiving assistive reproductive services. THIS MEDICAL CERTIFICATION MUST BE SUBMITTED ELECTRONICALLY WITH THE MEDICAL EXEMPTION REQUEST FORM AVAILABLE AT: https://mercysecure.formstack.com/forms/request_for_medical_exemption_from_seasonal_influenza_vaccination_2017 Date: 2
Co-worker Name: Request for Religious Exemption from Seasonal Influenza Vaccination Religious Leader Certification Form Mercy is committed to protecting its patients, co-workers, physicians, volunteers, and the public from the flu and, thus, has mandated that the above identified co-worker receive an influenza vaccination to further this commitment. As a healthcare organization, Patient Safety is a core value. Although not perfect, the influenza vaccination is the most effective way to prevent transmission of flu to patients. Mercy policy states that a religious exemption may be granted to accommodate sincerely held religious beliefs that prohibit an individual from obtaining the influenza vaccination. The individual identified above is requesting a religious exemption from this vaccination. Your supporting statements will assist us in evaluating this request. Please complete the information below for the above-named individual. I CERTIFY that the above-named individual has the following sincerely held religious beliefs requiring exemption from the influenza vaccination (attach additional pages if necessary): Church or Religious Body: Actions other than refusal to obtain vaccinations that demonstrate the above-named individual s sincerely held religious objection to the influenza vaccination: I AUTHORIZE Mercy to contact me directly if Mercy needs additional information and/or clarification about my knowledge of the above-named individual s religious beliefs and objections to the influenza vaccination. Name of Religious Leader/Attestor of Co-worker s religious beliefs: Signature of Religious Leader/Attestor of Co-worker s religious beliefs: Date: Phone Number: Address: THIS RELIGIOUS LEADER CERTIFICATION MUST BE SUBMITTED ELECTRONICALLY WITH THE RELIGIOUS EXEMPTION REQUEST FORM AVAILABLE AT: https://mercysecure.formstack.com/forms/request_for_religious_exemption_from_seasonal_influenza_vaccination_2017