Mandatory Vaccination Policy

I.    Purpose

Ursinus College is adopting this policy to safeguard the health of our employees and community members from the hazard of COVID-19. Vaccination is a vital tool to reduce the presence and severity of COVID-19 cases in the workplace, in communities, and in the nation as a whole.

II.    Scope

This policy applies to all employees regardless of position, job duties, and work location.

III.   Rules and Procedures


A.  Vaccination

Vaccination

All employees covered by this policy are required to be fully vaccinated no later than February 10, 2022 as a term and condition of employment at Ursinus College, unless they have requested and been approved for an exemption.

To be fully vaccinated by February 10, 2022, an employee must:

  • Obtain the second dose of a two-dose vaccine no later than January 27, 2022; or
  • Obtain one dose of a single dose vaccine no later than January 27, 2022.

Employees will be considered fully vaccinated two weeks after receiving the requisite number of doses of a COVID-19 vaccine, with, if applicable, the requisite interval in between. An employee will be considered partially vaccinated if they have received only one dose of a two-dose vaccine. While booster shots are strongly encouraged for those who are eligible, they are not currently required under this policy.

Vaccination Status and Acceptable Forms of Proof of Vaccination

All employees are required to provide proof of COVID-19 vaccination, regardless of where they received vaccination. Proof of vaccination status can be submitted using this link — https://ursinus.co1.qualtrics.com/jfe/form/SV_egjiVm5Z3UC3HrT

Acceptable proof of vaccination status is:

  1. The record of immunization from a health care provider or pharmacy; and/or
  2. A copy of the COVID-19 Vaccination Record Card.

Proof of vaccination generally should include the employee’s name, the type of vaccine administered, the date(s) of administration, and the name of the health care professional(s) or clinic site(s) that administered the vaccine. In some cases, state immunization records may not include one or more of these data fields, such as clinic site; in those circumstances Ursinus will still accept the state immunization record as acceptable proof of vaccination.

Employees must provide a physical copy of a vaccination record or provide a digital copy of acceptable records, including, for example, a digital photograph, scanned image, or PDF of such a record that clearly and legibly displays the necessary vaccination information.

All employees must inform Ursinus of their vaccination status. The following table outlines the requirements for submitting vaccination status documentation.

 

Vaccination Status

 

Instructions

 

Deadline

Employees who are fully vaccinated.

Submit proof of vaccination that indicates full vaccination.

January 10, 2022

Employees who are partially vaccinated (i.e., one dose of a two dose vaccine series).

Submit proof of vaccination that indicates when the first dose of vaccination was received, followed by proof of the second dose when it is obtained.

January 10, 2022

Employees who have not yet been vaccinated.

Submit statement that you are unvaccinated.

January 10, 2022

Employees who refuse to provide this information by the deadline will be subject to disciplinary action up to and including termination of employment.

Employees are strongly encouraged to review additional information about vaccinations at the website for the Center for Disease Control (CDC):

  • COVID-19 vaccine efficacy, safety, and the benefits of being vaccinated, “Key Things to Know About COVID-19 Vaccines,” available at https://www.cdc.gov/coronavirus/2019-ncov/vaccines/keythingstoknow.html);
  • the requirements of (to the extent applicable) 29 CFR 1904.35(b)(1)(iv), which prohibits the employer from discharging or in any manner discriminating against an employee for reporting work-related injuries or illness, and Section 11(c) of the OSH Act, which prohibits the employer from discriminating against an employee for exercising rights under, or as a result of actions that are required by, the ETS. Section 11(c) also protects the employee from retaliation for filing an occupational safety or health complaint, reporting a work-related injuries or illness, or otherwise exercising any rights afforded by the OSH Act (fact sheet available in English and Spanish); and
  • the prohibitions of (to the extent applicable) 18 U.S.C. § 1001 and of Section 17(g) of the OSH Act, which provide for criminal penalties associated with knowingly supplying false statements or documentation (fact sheet available in English and Spanish).

B.  Time Off and Leave for COVID-19

Vaccination Time Off

Any employee may take up to four hours during a workday to travel to the vaccination site, receive a vaccination, and return to work. This time off must be scheduled and coordinated with your supervisor. This time off will be available for both required doses in a two-shot vaccine. If you choose to get vaccinated outside of working hours, there will be no compensation for that time.

Recovery Time Off

We will also give time off for any employee who has side effects to a vaccine shot and is unable to work. Employees may take up to two workdays off immediately following each dose if they have side effects from the COVID-19 vaccination that prevent them from working.

Employees should consult with their supervisor, preferably before scheduling their vaccination.

C.  Employee Notification of Positive COVID-19 Test or Diagnosis and Removal from the Workplace

Employees must promptly notify Human Resources and their supervisor when they have tested positive for COVID-19 or have been diagnosed with COVID-19 by a licensed healthcare provider.

Isolation of Positive Cases from the Workplace

If an employee tests positive for COVID-19, the employee must stay home from work until the employee provides proof of one of the following:

  1.  If the initial positive result was from a COVID-19 antigen test, the employee can choose to seek a COVID-19 nucleic acid amplification test (NAAT) and can return to work by providing a negative NAAT result. The common PCR test is one type of NAAT, but a particular health care provider may use another test or type of PCR test. The test sample must be supervised or taken by a healthcare professional. 
  2.  The employee meets the return-to-work criteria in CDC’s “Isolation Guidance”, which at the time of this policy’s creation are as follows:

Under CDC’s “Isolation Guidance,” asymptomatic employees may return to work once 10 days have passed since the positive test. Symptomatic employees may return to work after all the following are true:

  • At least 10 days have passed since symptoms first appeared, and
  • At least 24 hours have passed with no fever without fever-reducing medication, and
  • Other symptoms of COVID-19 are improving (loss of taste and smell may persist for weeks or months and need not delay the end of isolation).

Employees who develop more severe symptoms should contact their supervisor and Human Resources and such instances will be handled under our normal leave policies.

D.  COVID-19 Testing

If an employee covered by this policy is not fully vaccinated (e.g., if they are still unvaccinated or partially vaccinated after the deadline, but are in the process; if they have a pending request for an exemption, or if they are granted an exemption from the mandatory vaccination requirement), the employee will be required to comply with this policy for testing beginning the week of February 7, 2022 (further details to be provided).

Employees who report to the workplace at least once every seven days:

    1. must be tested for COVID-19 at least once every seven days; and
    2. must provide documentation of the most recent COVID-19 test result to Human Resources no later than the seventh day following the date on which the employee last provided a test result.

Any employee who does not report to the workplace during a period of seven or more days (e.g., if they were teleworking for two weeks prior to reporting to the workplace):

  1.  must be tested for COVID-19 within seven days prior to returning to the workplace; and 
  2.  must provide documentation of that test result to Human Resources upon return to the workplace.

For all COVID-19 testing needs, the College is offering testing for its employees at no charge; in that situation, the documentation requirement is satisfied upon taking the test. Employees may substitute results of an antigen or NAAT test administered or monitored by a licensed health provider for this testing requirement; the employee will not be allowed to return to campus until the official result is provided to the college.

Employees who have received a positive COVID-19 test, or who have been diagnosed with COVID-19 by a licensed healthcare provider, are not required to undergo COVID-19 testing for 90 days following the date of their positive test or diagnosis.

E.  Face Coverings

All employees who are not fully vaccinated are required to wear a “face covering”, subject to certain exceptions in this policy. OSHA uses the term “face covering” to refer to what most call masks, and to distinguish from medical-grade masks.

Face coverings must: (i) completely cover the nose and mouth; (ii) be made with two or more layers of a breathable fabric that is tightly woven (i.e., fabrics that do not let light pass through when held up to a light source); (iii) be secured to the head with ties, ear loops, or elastic bands that go behind the head. If gaiters are worn, they should have two layers of fabric or be folded to make two layers; (iv) fit snugly over the nose, mouth, and chin with no large gaps on the outside of the face; and (v) be a solid piece of material without slits, exhalation valves, visible holes, punctures, or other openings. Review CDC guidelines for face coverings here.

Acceptable face coverings include clear face coverings or cloth face coverings with a clear plastic panel that, despite the non-cloth material allowing light to pass through, otherwise meet these criteria and which may be used to facilitate communication with people who are hearing impaired or others who need to see a speaker’s mouth or facial expressions to understand speech or sign language respectively.

Employees who are not fully vaccinated must wear face coverings over the nose and mouth when indoors and when occupying a vehicle with another person for work purposes. Policies and procedures for face coverings will be implemented, along with the requirements of applicable law, as part of a multi-layered infection control approach for unvaccinated workers.

The following are exceptions to the requirements for face coverings:

  1. When an employee is alone in a room with floor to ceiling walls and a closed door.
  2. For a limited time, while an employee is eating or drinking at the workplace or for identification purposes in compliance with safety and security requirements.
  3. When an employee is wearing a respirator or facemask.
  4. Where Ursinus has determined that the use of face coverings is infeasible or creates a greater hazard (e.g., when it is important to see the employee’s mouth for reasons related to their job duties, when the work requires the use of the employee’s uncovered mouth, or when the use of a face covering presents a risk of serious injury or death to the employee).

F.   New Hires

All new employees are required to comply with the vaccination requirements outlined in this policy as soon as practicable and as a condition of employment. Potential candidates for employment will be notified of the requirements of this policy prior to the start of employment.

G.   Confidentiality and Privacy

All medical information collected from individuals, including vaccination information, test results, and any other information obtained as a result of testing, will be treated in accordance with applicable laws and policies on confidentiality and privacy. These records will need to be maintained and may need to be disclosed to OSHA or as otherwise required by law.

H.   Reasonable Accommodations

If an employee needs a reasonable accommodation from any part of this policy, the employee should submit a request for accommodation using the form found here. This includes any request for an exemption based upon medical/disability or religious reasons. All such requests will be handled in accordance with applicable laws and regulations and the College’s applicable policies and procedures.

I.   Enforcement and Discipline

Employees must provide truthful and accurate information about their COVID-19 vaccination status, and, if not fully vaccinated (e.g., due to an exemption), their testing results. Failure to follow this Policy will lead to disciplinary action up to and including termination of employment.

The following is a non-exhaustive list of actions that would violate this policy and subject an employee to discipline up to and including termination:

  • Failure to provide vaccination status
  • Failure to provide appropriate proof of vaccination
  • Providing false documents
  • Failure to follow mask policies if you are unvaccinated
  • Failure to comply with all testing policies, including prompt and accurate reporting of tests
  • Failure to disclose a positive diagnosis, or other notifications required by this policy
  • Failure to follow any other directions and requirements

Employees who are required to take weekly COVID-19 tests but do not upload their results according to this Policy are not permitted to report to work, either in the office or remotely. An employee’s absence for this reason will be treated as an unexcused absence and the employee will be subject to disciplinary action up to and including termination of employment.

J.   Questions

Please direct any questions regarding this policy to Kelley Williams, Associate Vice President for Human Resources.