CDC guidance on employer vaccination programs

The CDC on March 16 issued new guidance on workplace vaccination programs that offers suggestions to help employers increase vaccine uptake among essential workers, but the suggestions also apply for other types of employees. According to the CDC, even though the vaccine supply may at this point still be limited, it’s not too early for employers to share clear, complete, and accurate messages; promote confidence in the decision to get vaccinated; and engage employees in plans to address potential vaccination barriers.

"Strong confidence in the vaccines within your workplace leads to more people getting vaccinated, which leads to fewer COVID-19 illnesses, hospitalizations, and deaths," the CDC said. The broad guidance addresses a range of topics from building confidence in vaccinations and determining when employees can get vaccinated, to choosing between and implementing onsite and offsite options, best practices, avoiding worker shortages due to vaccine side effects, and workplace reopening.

Onsite and offsite options. Onsite vaccination options include onsite administration through existing occupational health clinics, employer-run temporary vaccination clinics, and mobile vaccination clinics brought to the workplace. Offsite options include through mobile/temporary vaccination clinics set up at community locations (closed or open to the public), pharmacies enrolled in the Federal Retail Pharmacy Program, hospitals and healthcare provider offices, federally qualified health centers, and other community clinics.

Workplace vaccination programs. Employers should consider a workplace vaccination program where they have:

• A large number of workers onsite with predictable schedules;
• Ability to enroll with their jurisdiction’s immunization program as a vaccination provider, including appropriately training staff, or to engage an enrolled vaccination provider; or
• A location with enough space to stand up a vaccination clinic while maintaining social distancing through the entire process, from screening to post-vaccination observation (see CDC guidance for temporary vaccination clinics for more detail).

Onsite vaccination checklist. The CDC offered what amounts to a checklist for onsite vaccination programs:

• The planning process for hosting a workplace COVID-19 vaccination program should include input from management, HR, employees, and labor representatives, if present.
• Employers considering implementing a workplace COVID-19 vaccination program should contact the health department in their jurisdiction for guidance.
• Employers may want to engage a community vaccination provider/vendor; these typically deliver worksite flu vaccination services, are expanding to provide COVID-19 vaccination, have trained nursing staff available in all jurisdictions, can bill insurance for administration fees, and can report vaccine administration data to immunization registries.
• Vaccination providers must prepare to monitor for and manage potential anaphylaxis after vaccination.
• Workplace vaccination clinics must offer vaccination at no charge and during work hours.
• Workplace vaccination clinics must provide easy access to vaccination for all people working at the workplace, regardless of status as a contractor or temporary employee.

See the National Institute of Health’s Key Elements of a Model Workplace Safety and Health COVID-19 Vaccination Program.

Offsite vaccination programs. Employers should consider offsite vaccination if they:

• Are a small- or medium-sized organization that does not have the resources to host a vaccination clinic;
• Have mobile worker populations that frequently move from one job site to the next;
• Have workers with highly variable schedules; or
• Have a majority of workers who would prefer vaccination in a community clinic rather than an employer-run clinic.

Checklist for encouraging offsite vaccination. The CDC similarly offered what can be considered a checklist for encouraging offsite vaccination when an onsite program is not feasible:

• Allow employees to get vaccinated during work hours or take paid leave to get vaccinated at a community site.
• Support transportation to offsite vaccination clinics, such as paying fares for taxis or ridesharing services, and ensuring employees can maintain social distancing. Check the local health department(s) about potential assistance, such as a mobile clinic or transportation support.
• In jurisdictions where there are screening requirements to ensure that only those who are eligible are vaccinated, let employees know what they will need to bring with them to be vaccinated (employee ID badge or name tag, voucher, etc.).
• Post articles in company communications, such as newsletters, intranet, emails, portals, etc., about the importance of COVID-19 vaccination, as well as how and where to get the vaccine in the community.
• Educate and help workers who are eligible for vaccination go make appointments through available channels.
• Make sure employees know that COVID-19 vaccines are provided free of charge, and that they should not be asked to pay any fee, including a vaccine administration fee, and cannot be denied vaccine if they do not have insurance coverage. However, providers may bill their insurance plan or program for the administration fee if they have insurance.
• Identify other potential barriers unique to the employer’s workforce and implement policies and practices to address them.

Communications about vaccination. The CDC suggests that employers build confidence in recommended vaccines, vaccine administrators, and the process through which vaccines were developed, authorized, manufactured, and recommended. The federal health protection agency offered a series of steps through which employers can make vaccine confidence visible in the workplace:

1. Encourage leaders to be vaccine champions. These leaders should reflect the diversity of the workforce. Invite them to share with staff their personal reasons for getting vaccinated and remind staff why it’s important to be vaccinated;

2. Communicate transparently to all workers about vaccination (see Key Things to Know, Frequently Asked Questions, and Myths and Facts for up-to-date information);

3. Create a communication plan that shares key messages with staff through breakroom posters, emails, and other channels. Emphasize the benefits of protecting themselves, their families, coworkers, and community (see fact sheet available in numerous languages);

4. Provide regular updates on topics such as the benefits, safety, side effects, and effectiveness of vaccination, and clearly communicate what is not known; and

5. Make visible the decision to get vaccinated and celebrate it, for example, by providing stickers for workers to wear after vaccination and encouraging them to post selfies on social media.

Toolkit. The CDC also noted that it has created the COVID-19 Vaccine Communication Toolkit for Essential Workers to help employers reinforce confidence in vaccination, including through FAQs for employers and employees.

Best practices. Regardless of whether vaccinations are provided at the workplace or offsite, the CDC offered these best practices for employers:

• Offer flexible, non-punitive sick leave options, such as paid sick leave, for employees with signs and symptoms after vaccination.
• Allow time for vaccine confidence to grow; workers who are hesitant at first may become more confident after seeing coworkers get vaccinated. Thus, employers with an onsite clinic should offer more than one opportunity for vaccination; mobile clinics can return to a worksite multiple times on a rotating schedule. Employers using community locations can provide supportive policies, such as paid leave and transportation support, for an extended period of time.
• Ask organizations and individuals who are respected in employee communities to help build confidence in COVID-19 vaccines.

Avoiding worker shortages. The CDC also suggested that employers consider staggering employee vaccinations to avoid worker shortages due to vaccine side effects. Most side effects are mild, occur within the first three days of vaccination, and resolve within one-to-two days. Side effects are more frequent and severe following the second dose of a two-dose vaccine. The CDC currently expects that most employees who experience symptoms will not need to miss work, but it still encourages employers to provide flexible leave policies for those who may have post-vaccination symptoms.

Further, for employees who receive a two-dose vaccine, staggering may be more important for the second dose, after which side effects are more common. To help ensure continuity of operations, employers may consider staggering vaccination for employees in the same job category or who work in the same area of a facility. Staggering vaccination for employees may cause delays in vaccinating the staff, and so the decision to stagger vaccination will need to be weighed against potential inconveniences that might reduce vaccine acceptance. Facilities that choose to stagger vaccine administration should also ensure that all employees receive the recommended number of doses.

Contractors and temp employees. Where workers are employed by contract firms or temporary help agencies, the staffing agency and the host employer are joint employers and thus, are both are responsible for providing and maintaining a safe work environment, according to the CDC. Because the extent of the responsibilities that the staffing agency and the host employer have will vary depending on the workplace conditions, these responsibilities should be described in the contract (see Protecting Temporary Workers).

Employers that plan to offer workplace vaccination should consider providing vaccination to all people working at the workplace, regardless of their status as a contract or temporary employee. "What is most important is to encourage everyone at the work site to be vaccinated, no matter what their work arrangement is," the CDC said. Where employers do not plan to or are unable to offer worksite vaccination, they should consider providing information to those who are at the workplace on how to explore options for vaccination in the community.

Vaccination mandates. The guidance also provides a discussion of employer vaccination mandates and proof of vaccination, noting that whether employers may require or mandate COVID-19 vaccination is a matter of state or other applicable law. As to proof of vaccination, employers cannot mandate that the employee provide any medical information as part of the proof.

There are two exemptions that employers may implement:

1. Medical exemptions for people who may be at risk for an adverse reaction because of an allergy to one of the vaccine components or a medical condition.

2. Religious exemptions for people who may decline vaccination because of a religious belief.

Employers offering vaccination to workers should keep a record of the offer to vaccinate and the employee’s decision (see EEOC guidance).

Reopening workplaces. Among other things, the CDC’s guidance offered several insights on reopening workplaces following vaccination. In work settings, even after employees receive a COVID-19 vaccine, they may still need to take steps to protect themselves and others in many situations. Employers should continue to follow the Guidance for Businesses and Employers Responding to COVID-19, including wearing well-fitting masks, social distancing, washing hands, and encouraging employees to stay home if sick. Other workplace health and safety measures, such as engineering controls (e.g., barrier protections), that were installed should remain in place.

Workplace assessment. Employers should also conduct a thorough workplace assessment to identify potential workplace hazards related to COVID-19. While widespread employee vaccination may be one consideration for restarting operations and returning to the workplace, other factors should be considered, including these:

• The necessity for employees to physically return to the workplace and whether telework options can be continued;
• Transmission of COVID-19 in the community (how many infections there are and how fast it’s spreading);
• The ability of employees to practice social distancing and other prevention measures, such as wearing masks, when in the workplace; and
• Local or state mandates for business closure restrictions.

From WCI's HR Answers Now ©2021 CCH Incorporated and its affiliates. All rights reserved.