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Howard Community College COVID-19 Vaccination, Testing, and Face Covering Procedure – 63.10A.01-COVID

College Policy Number/Title:

Overview and General Information

Vaccination
Any Howard Community College (HCC) employee who chooses to or is required to be vaccinated against COVID-19 must be fully vaccinated no later than December 1, 2021. Any employee not fully vaccinated by December 1, 2021, will be subject to the regular testing and face covering requirements of the policy and procedure.

Employees will be considered fully vaccinated two weeks after receiving the requisite number of doses of a COVID-19 vaccine. An employee will be considered partially vaccinated if they have received only one dose of a two-dose vaccine.

The Howard County Health Department and many pharmacies, retailers, and physicians’ offices offer the COVID-19 vaccine free of charge. Visit the Howard County Health Department website for clinic dates and locations. This policy will be maintained by the vice president of administration and finance.

Testing and Face Coverings
All employees who are not fully vaccinated as of December 1, 2021, are required to undergo regular COVID-19 testing, using the polymerase chain reaction (PCR) test. All employees, regardless of vaccination status, are required to wear a face covering when in the workplace. Policies and procedures for testing are described in the relevant sections of this procedure.

Vaccination Status and Acceptable Forms of Proof of Vaccination
All vaccinated employees are required to provide proof of COVID-19 vaccination, regardless of where they received vaccination. Proof of vaccination status can be submitted via Azova, a secure third-party, HIPAA-certified portal site, to manage vaccination and testing records. Only select human resources and emergency operations staff members are able to review vaccination cards and testing results.

Acceptable proof of vaccination status includes:

  1. the record of immunization from a health care provider or pharmacy
  2. a copy of the COVID-19 Vaccination Record Card
  3. a copy of medical records documenting the vaccination
  4. a copy of immunization records from a public health, state, or tribal immunization information system or
  5. a copy of any other official documentation that contains the type of vaccine administered, date(s) of administration, and the name of the health care professional(s) or clinic site(s) administering the vaccine(s).

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 HCC will still accept the state immunization record as acceptable proof of vaccination.

If an employee is unable to produce one of these acceptable forms of proof of vaccination, despite making every attempt to do so (e.g., by trying to contact the vaccine administrator or state health department), the employee can provide a signed and dated statement attesting to their vaccination status. The attestation should state that they have lost and are otherwise unable to produce one of the other forms of acceptable proof and should include the following language:

“I declare (or certify, verify, or state) that this statement about my 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.”

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 health care professional(s) or clinic site(s) administering the vaccine. The attestation must be signed, dated, and reported to Azova.

Employees must create an account with Azova and submit vaccination records. Azova verifies all vaccination and testing records against a national database to ensure accuracy. Submitting a false vaccination card or a false attestation is a felony under Title 18 of the US Code, Section 10-17. That violation could carry a fine and a maximum of five years in prison.

All employees, both vaccinated and unvaccinated, must inform Howard Community College of their vaccination status. Employees who do not submit proof of COVID-19 vaccination are required get a PCR test for COVID-19 at least once per week and submit the results to Azova.

Supporting COVID-19 Vaccination
An employee may take up to four hours of duty 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 duty time for employees receiving two doses. If an employee spends less time getting the vaccine, only the necessary amount of leave 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., they may need to travel long distances to get the vaccine). Any additional time requested will be granted, if reasonable, 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 duty 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 leave for obtaining the COVID-19 vaccine or using sick leave to recover from side effects, the employee and supervisor should use established leave request procedures.

Employee Notification of COVID-19 and Removal from the Workplace
Howard Community College requires employees to promptly notify their supervisor when they have tested positive for COVID-19 or have been diagnosed with COVID-19 by a licensed healthcare provider. Employees should review college procedure 63.08.14, Sick and Disability Leave or Absence for questions regarding use of leave.

Medical Removal from the Workplace
HCC requires that an employee immediately leaves the workplace if that employee has received a positive COVID-19 test or has been diagnosed with COVID-19 by a licensed healthcare provider.

  • Employees who report or demonstrate having a suspected or confirmed positive COVID-19 diagnosis, COVID-19 related symptoms, or close contact with someone without a face covering who has symptoms or a confirmed COVID-19 diagnosis must leave campus immediately. Close contact is defined as within six feet for 15 minutes or more.
  • Employees must notify their supervisor immediately via email with a copy to eop@howardcc.edu and provide their name, campus location, and building and room number.
  • Consult procedure 63.06.10, Telework for guidelines on working remotely.

Return to Work Criteria
Any employee removed from the workplace because they received a COVID-19 positive test or diagnosis by a licensed healthcare provider, is prohibited from returning to the workplace until one of the following is fulfilled:

  • receives a negative result on a COVID-19 nucleic acid amplification test (NAAT) following a positive result on a COVID-19 antigen test if the employee chooses to seek a NAAT test for confirmatory testing;
  • meets the return to work criteria in the CDC’s “Isolation Guidance”; or
  • receives a recommendation to return to work from a licensed healthcare provider.

Employee’s must follow the CDC’s Isolation Guidance before returning to work.

If an employee has severe COVID-19 or an immune disease, HCC will follow the guidance of a licensed healthcare provider regarding return to work.

COVID-19 Testing
All employees who are not fully vaccinated or do not submit proof of vaccination status are required to comply with this procedure for testing. These employees must get a PCR test at least once per week and submit the results. If an employee does not provide documentation of a test result as required, they will be subject to disciplinary action.

Any unvaccinated employee who does not report to the workplace during a period of seven or more days (e.g., FMLA leave, traveling abroad, other extended absence), excluding week-long college closures such as winter break and spring break:

  • must be tested for COVID-19 within seven days prior to returning to the workplace; and
  • must submit documentation of that test result to Azova upon return to the workplace.

If an employee does not provide documentation of a COVID-19 test result as required, they will be unable to return to the workplace until they provide a negative test result and will be subject to disciplinary action.

Employees who have received a positive COVID-19 test or 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.

For information on how to get tested for COVID-19, visit the Howard County Health Department website.

Face Coverings
Howard Community College requires face coverings for all employees, regardless of vaccination status. Face coverings must be worn indoors in every college building and facility and when occupying a vehicle with another person for work purposes. Face coverings must: completely cover the nose and mouth; 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); 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; fit snugly over the nose, mouth, and chin with no large gaps on the outside of the face; and be a solid piece of material without slits, exhalation valves, visible holes, punctures, or other openings. 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 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. 

Employees should contact their supervisor to obtain a face covering if needed.

The following are exceptions to Howard Community College’s requirements for face coverings:

  1. When an employee is alone in a room with floor to ceiling walls.
  2. When an employee is alone at their desk in an open space with six feet distance.
  3. 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.
  4. When an employee is wearing a respirator or facemask.
  5. Where Howard Community College 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).

New Hires
All new employees are required to comply with the vaccination, testing, and face covering requirements outlined in this policy and procedure 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.

Employees will be provided with instruction on how to upload their vaccination documents during the human resources onboarding process.

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.

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal law that required the creation of national standards to protect sensitive patient health information from being disclosed without the patient’s consent or knowledge. Howard Community College is using Azova, a secure third-party, HIPAA-certified portal site, to manage vaccination and testing records. HIPAA certification requires more standards than HIPAA compliance; certification requires passing a test related to HIPAA compliance and the HIPAA Security Rule, a specific subset of HIPAA guidelines that establishes standards for both physical protected health information (PHI) and electronic PHI (ePHI). The Privacy Rule standards address the use and disclosure of individuals’ PHI and the organization’s responsibility for implementing all administrative, physical, and technical measures necessary to protect patient data.

Questions
Please direct any questions regarding this policy to eop@howardcc.edu or HumanResources@howardcc.edu.

Effective Date: 02/11/22

President’s Office Use: VPAF/PRES

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