18.1.04 - Influenza & COVID-19 Vaccination Policy
Public Health & Safety: Public Health
Last Updated: 09/29/2021
Original policy date: 03/30/2016
Applies to: Faculty, Staff, Residents & Clinical Postdoctoral Fellows, Postdoctoral Fellows, Students
Policy Status, Date of Last Review
Current, as of September 14, 2021
Next Scheduled Review Date
September 30, 2021
· On the World Health Organization Emergency Use Listing (WHO EUL);
· Approved for distribution in the U.S. by the Food and Drug Administration (FDA) or has FDA Emergency Use Authorization (EUA) approval; OR
· Approved for BCM community use by BCM OHP and BCM Infectious Disease, in accordance with advice provided by the CDC Advisory Council on Immunizations Practices.
a. All BCM Learners and Employees must complete Flu Vaccination by the annual deadline, as established by the Medical Director of the OHP. All new Employees must receive a Flu Vaccination within 60 days of hire.
b. All BCM Employees must complete COVID-19 Vaccination by the announced deadline, as established by the Medical Director of the OHP. All new Employees must complete COVID-19 Vaccination within 60 days of hire.
c. These deadlines may be changed based on market conditions (e.g., postponed due to delays in vaccine distribution) or other relevant considerations (e.g., outbreaks in the local community).
d. Employee noncompliance with any of these Vaccination requirements, as evidenced by attestation (see Section IV.A.3, below) or exemption request submission (see Section IV.B, below) on or before the applicable deadline, will result in an employment action up to and including termination.
a. For Influenza, each Learner or Employee must self-attest to receipt of the Flu Vaccination or exemption request through an online portal. Learners and Employees who choose to receive a Flu Vaccination elsewhere (e.g., affiliate, local pharmacy, physician’s office, health department), must produce a record documenting any required vaccination upon request. Upon completion, each Learner or Employee who receives a required vaccine through a third-party must self-attest through the online portal.
b. For COVID-19, Employees must self-attest to receipt of complete COVID-19 Vaccination or exemption request through an online portal. Employees who choose to receive COVID-19 Vaccination elsewhere (e.g., affiliate, local pharmacy, physician’s office, health department), must produce a record documenting any required vaccination upon request. Upon completion, each Employee who receives a required vaccination through a third-party must self-attest through the online portal.
c. BCM may periodically request verification of documentation from Learners and Employees who self-attested.
1. Scope. BCM will recognize the following exemptions to the Influenza and COVID-19 Vaccination requirements, provided that the requestor submits an acceptable Exemption Request Form with required documentation (see Section IV.B.3, below).
a. Medical exemptions are allowed if an individual is unable to receive a Flu or COVID-19 Vaccination due to their own disability or medical condition. Completed exemption request forms must be signed by a U.S.-licensed Independent Provider (i.e., M.D., D.O., N.P., P.A.). The exemption request must indicate if it is short term. Individuals whose exemption is short term shall begin vaccination within 60 days of their exemption expiration date.
b. Religious exemptions are allowed if an individual is unable to receive a COVID-19 Vaccination due to their sincerely held religious beliefs, practices or observances. Exemption requests must be documented on the Vaccination Exemption Request Form.
2. Exemption Request Deadlines.
a. Influenza – Exemption requests are due at least 30 days before any applicable vaccination deadline. For persons joining BCM after the annual deadline has passed, Flu exemption requests are due within 60 days of their start date.
b. COVID-19 – Exemption requests are due at least 14 days before any applicable vaccination deadline. For persons new to BCM, COVID-19 exemption requests are due within 60 days of their start date.
3. How to Request a Flu or COVID-19 Vaccination Exemption. Individuals who wish to request a vaccination exemption MUST complete a Vaccination Exemption Request Form and submit appropriate supporting documentation as provided below:
a. Individuals must submit the Exemption Request Form via Power Apps. Forms must be complete to be considered. Incomplete submissions are not considered valid.
b. Exemption requests will be reviewed by BCM Occupational Health. A determination will be provided to the individual via BCM email.
c. If a request is not approved, an individual shall complete vaccination and provide proof of vaccination within 60 days to BCM Occupational Health.
4. Duration of Approved Exemptions. Short-term vaccination exemptions are valid for at most one-year after which the individual may resubmit a Vaccination Exemption Request Form for consideration to extend the exemption.
5. Anti-Retaliation. In accordance with Baylor’s Policy Regarding Harassment, Discrimination, and Retaliation (02.2.25), retaliation, discrimination, and harassment against persons exempted from one or more vaccination requirements are prohibited.
1. Individuals exempted from otherwise required vaccinations under this policy must take alternate steps to safeguard the health of themselves, BCM patients, Employees, Learners, and their families. If there is not a BCM wide general masking policy in place, those exempted from vaccination must wear masks at all times during scheduled shifts and/or while present in BCM facilities in BCM facilities in accordance with OHP requirements. The Medical Director of the OHP determines when masks are required and announces masking directives based on the prevalence of viral disease in the community. Refer to BCM’s mask and face covering guidelines during a pandemic here. Employees or Learners who do not comply with these alternative requirements may be subject to progressive discipline up to and including termination.
2. BCM affiliates may require an individual to be vaccinated prior to coming onsite at their locations and/or providing services under contracts they have with BCM regardless of whether an exemption applies.
3. When an individual’s inability to be vaccinated prevents them from performing essential functions of their job or course of study due to such an affiliate requirement, BCM cannot guarantee that alternate work assignments will be available and lack of vaccination may result in termination of employment or course of study.
4. Trainees and Learners must be aware that inability to meet vaccination or other requirements of an affiliate where they are assigned for clinical, residency, or other training required by their programs may render them unable to complete their course of study or receive degrees or certifications demonstrating completion of training.
5. The process described in this policy is separate and distinct from the Americans with Disabilities (ADA) accommodation request procedure for workplace accommodations. All continued and new requests for accommodations due to an employee’s own medical condition (whether or not Flu or COVID-19-related) must go through the ADA process.