COVID-19 Vaccination Policy
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. While Iona College did not initially adopt a mandatory vaccination policy, OSHA recently required that employers with 100 or more employees must have mandated vaccination protocols or testing of unvaccinated employees weekly. The College strongly recommends that all Iona community members get vaccinated and boosted. To safeguard the health of our campus from the hazard of COVID-19, employees who are not vaccinated are required to be tested for COVID-19 on a weekly basis and submit results to identify those who are Covid–19 positive. This policy complies with OSHA’s Emergency Temporary Standard on Vaccination and Testing (29 CFR 1910.501). This policy is subject to change as circumstances evolve and guidance from OSHA, CDC and the State of NY are updated.
This Vaccination Policy applies to all employees of Iona College, except for employees who exclusively work remotely.
All employees covered by this policy are required to be fully vaccinated by January 29, 2022. If not fully vaccinated by January 29, 2022, employees must submit weekly covid test results through the College’s HRIS system, Paycom. Employees are considered fully vaccinated 14 days after receiving the COVID-19 vaccine, as per CDC guidelines. Employees must provide truthful and accurate information about their COVID-19 vaccination status, and, if applicable, their test results. Employees who are not in compliance with this policy will be subject to disciplinary action.
Employees may request an exemption from receiving the Covid-19 Vaccine if the vaccine is medically contraindicated for them.
Employees also may be legally entitled to a reasonable accommodation if they cannot be vaccinated and/or wear a face mask related to a pre-existing disability, or if the provisions in this policy for vaccination, and/or testing for COVID-19, and/or wearing a face mask conflict with a sincerely held religious belief, practice, or observance. Requests for exceptions and reasonable accommodations must be submitted to the Director of Human Resources with documentation sufficient to validate the request. All such requests will be handled in accordance with applicable laws and regulations.
The medical exemption form must be signed by a licensed medical practitioner and include justification for not receiving the vaccine. The medical exemption form must include the employee's name, employee number, date of birth and signature of employee and date of submission.
Vaccination Status and Acceptable Forms of Proof of Vaccination
All vaccinated employees are required to provide proof of COVID-19 vaccination. Proof of vaccination status is uploaded to Paycom the College’s HRIS system, or a hard copy of their vaccine card is submitted to the Human Resources office.
The following will be considered as acceptable proof of vaccination:
- the copy of immunization from a healthcare provider or pharmacy;
- a copy of the COVID-19 Vaccination Record Card;
- a copy of medical records documenting the vaccination dated and signed by the healthcare provider
- a copy of immunization records from a public health, state, or tribal immunization information system; or
- a copy of any other official documentation that contains the type of vaccine administered, date(s) of administration, and the name of the healthcare professional(s) or clinic site(s) administering the vaccine(s).
Proof of vaccination MUST include the employee’s FULL name, DATE OF BIRTH, VACCINE MANUFACTURER, LOT NUMBER, the date(s) of administration, and the name of the healthcare 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 the College will still accept the state immunization record as acceptable proof of vaccination.
If after making a bona fide attempt (e.g., by trying to contact the vaccine administrator or state health department), an employee is unable to produce acceptable proof of vaccination, the employee may provide a signed and dated statement attesting to their vaccination status (fully vaccinated or partially vaccinated); attesting that they have lost or are otherwise unable to produce acceptable proof; and including the following language:
“I declare (or certify, verify, or state) that this statement about my Covid-19 vaccination status is true and accurate. I understand that knowingly providing false information regarding my vaccination status on this form may subject me to criminal penalties and/or workplace discipline.”
An employee who attests to their vaccination status in this way should, to the best of their recollection, include in their attestation the type of vaccine administered, the date(s) of administration, and the name of the healthcare professional(s) or clinic site(s) administering the vaccine.
All employees must inform the college of their vaccination status. The following table outlines the requirements for submitting vaccination status documentation.
Employees who are fully vaccinated.
Submit proof of vaccination that indicates full vaccination.
January 29, 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 29, 2022
Employees who have not yet been vaccinated.
Submit statement that you are unvaccinated.
January 29, 2022
Supporting COVID-19 Vaccination
An employee may take up to four hours of work time per dose to travel to the vaccination site, receive a vaccination, and return to work. This would mean a maximum of eight hours of work time for employees receiving two doses. If an employee spends less time getting the vaccine, only the necessary amount of work time will be granted. Employees who take longer than four hours to get the vaccine must send their supervisor an email documenting the reason for the additional time (e.g., travelling a long distance to get the vaccine). If reasonable, additional time will be granted, but will not be paid; in that situation, the employee can elect to use accrued leave, e.g., sick leave, to cover the additional time. If an employee is vaccinated outside of their approved work time, they will not be compensated.
Employees may utilize up to two workdays of sick leave immediately following each dose if they have side effects from the COVID-19 vaccination that prevent them from working. Employees who have no sick leave will be granted up to two days of additional sick leave immediately following each dose if necessary.
To request work time to obtain the COVID-19 vaccine or sick leave to recover from side effects, employees should email their supervisor/manager of their plan to get vaccinated or need for sick time post vaccine. The employee should alert their manager to the date and time of the scheduled vaccine. A copy of the email should be sent to firstname.lastname@example.org for time tracking purposes. The Human Resources team will ensure the time is properly documented for payroll purposes.
Employee Notification of COVID-19 and Removal from the Workplace
Iona College requires employees to immediately notify Human Resources when they have tested positive for COVID-19 or have been diagnosed with COVID-19 by a licensed healthcare provider. Employees can email email@example.com from home or at work.
Medical Removal from the Workplace
Iona College has also implemented a policy for keeping COVID-19 positive employees out of the workplace in certain circumstances. An employee who has a positive COVID-19 test or has been diagnosed with COVID-19 by a licensed healthcare provider will be excused from campus (i.e., immediately sent home or to seek medical care, as appropriate). When an employee converts to positive while on campus the employee is instructed to contact HR informing HR on their positive status. The employee is instructed to immediately go home or seek immediate medical attention if warranted. The length of isolation is based on current Westchester County Department of Health guidelines. The length of isolation is completing 5 days of isolation with return to work on Day 6 if the employee remains asymptomatic within 48 hours of return to work. Employees should not take fever reducing medications to control fever within 48 hours of return to work.
Exposure is defined as an employee being in direct contact with a positive person for more than 15 minutes within 6 feet of distance.
Return to Work Criteria
- An employee infected with COVID-19 must isolate for five days, where day zero is the day of symptom onset, or (if asymptomatic) the day of collection of a positive test result.
- Employees may return to work after completing 5 days of isolation, returning to work on the 6th day if the employee is asymptomatic. The employee should not exhibit fevers, runny noise (rhinitis) or cough. Employees should not take fever reducing medications to reduce fevers.
- If other symptoms are resolving, employees may return to work.
- If an infected employee is asymptomatic after five days, or if symptoms are resolving, they can end isolation and return to work but must wear a well-fitting face mask around others for an additional five days. Individuals who cannot wear a well-fitting mask around others should continue to follow the standard isolation guidance (10 days).
- Employees who are moderately or severely immunocompromised should continue to follow the standard isolation guidance (10 days).
- For employees who are fully vaccinated and boosted (with the booster RECEIVED THE MINIMUM OF 14DAYS PRIOR TO EXPOSURE, no quarantine is required. Employees are required to wear a well-fitting mask for 10 days after the last date of exposure. A Covid test is required to be completed on Day 5. Results must be uploaded to Paycom.
- Employees who are not fully vaccinated, fully vaccinated and did not receive a booster dose greater than 14 days from last exposure must quarantine for five days and wear a well-fitting mask while around others for an additional five days. A Covid test is required to be completed on Day 5 and results must be uploaded into Paycom.
- If symptoms appear for either set of individuals, the individual should immediately quarantine and seek testing. In this scenario, quarantine ends upon a negative test, or upon following the guidance described in the “Infected” section above.
If an employee covered by this policy is not fully vaccinated, the employee will be required to undergo weekly testing.
Employees who report to the workplace at least once every seven days:
(A) must be tested for COVID-19 at least once every seven days; and
(B) must provide documentation of the most recent COVID-19 test result to Human Resources via the Paycom portal 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):
(A) must be tested for COVID-19 within seven days prior to returning to the workplace; and
(B) must provide documentation of that test result to Human Resources upon return to the workplace.
If an employee does not provide documentation of a COVID-19 test result as required by this policy, they will not be allowed to work on campus until they provide a test result. The employee will be subject to disciplinary action for non-compliance with testing requirements.
Employees who have received a positive COVID-19 test or have been diagnosed with COVID-19 by a licensed healthcare provider must comply with all relevant provisions of this policy but are not required in addition to undergo COVID-19 testing for 90 days following the date of their positive test.
Employees will have the option to test on campus for a fee or may test off campus on their own time. Self-administered home tests will not be accepted. The test results must include the employee’s name, date of birth and date of test. Test result documentation must be uploaded to Paycom each week.
All employees, regardless of vaccination status, must wear face masks over the nose and mouth when indoors and when occupying a vehicle with another person for work purposes. Policies and procedures for face masks will be implemented, along with the other provisions required by OSHA’s COVID-19 Vaccination and Testing ETS, as part of a multi-layered infection control approach for unvaccinated workers.
Face masks 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. Acceptable face masks include clear face masks or cloth face masks 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 deaf or hard-of-hearing or others who need to see a speaker’s mouth or facial expressions to understand speech or sign language respectively.
The following are exceptions to the College’s requirements for face masks:
- When an employee is alone in a room with floor to ceiling walls and a closed door.
- For a limited time, while an employee is eating or drinking or for identification purposes in compliance with safety and security requirements.
- When an employee is wearing a respirator.
- When the College has determined that the use of a face covering 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).
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.
Confidentiality and Privacy:
All medical information collected from individuals, including vaccination information, test results, and any other information obtained because of testing, will be treated in accordance with applicable laws and policies on confidentiality and privacy.
Please direct any questions regarding this policy to Human Resources Department at firstname.lastname@example.org.