HR: COVID-19 Vaccinations

Purpose

Head Start of Lane County (“Head Start”) is dedicated to returning, to the extent possible, to a lively and dynamic center where all Head Start students can flourish. Head Start is also committed to advancing the health of Head Start students, staff, and community members, promoting the safety of our in-person learning environment, and contributing to the decline of the novel coronavirus disease 2019 (COVID-19) pandemic.

Like the Oregon Health Authority (OHA), Head Start’s priority is to implement the protocols needed to reliably hold pre-school in-person, every pre-school day, for all students, all year long. The Delta variant of COVID-19 has driven the highest hospitalization rates Oregon has seen throughout the COVID-19 pandemic. Currently, vaccines are only available to those 12 and older. As a result, the students Head Start serves are not vaccinated.

After careful deliberation, and consideration of federal, state, and local laws, rules, and guidelines, including without limitation OAR 333-019-1030, Head Start is requiring all employees to be vaccinated against COVID-19 to be employed by Head Start. By requiring staff and volunteers to be vaccinated, and requiring an indoor face-covering (or mask) rule, we are decreasing the likelihood of students and staff becoming exposed to COVID-19.

Policy

Proof of full vaccination is required for employees—including without limitation teachers, substitute teachers, administrative staff, school nurses, temporary staff, and drivers—and volunteers to return Head Start centers for the 2022-2023 School Year by the date(s) outlined below. Parents or other family members who volunteer at the Head Start center are subject to this policy and are required to comply. Short-term visitors or individuals making deliveries are not subject to this policy.

Any vaccine authorized for use in the United States is acceptable—namely Pfizer-BioNTech, Moderna, and Johnson & Johnson/Johnson (J&J). An individual must be up to date with their vaccinations against COVID-19 by the schedule stated below to be at the Head Start center.  At Head Start, people are considered “up to date”:

• For individuals who received a primary series of Pfizer, they are up to date “immediately after getting all boosters recommended for”:
  • Boosters: 
    • 1 booster, preferably of either Pfizer or Moderna COVID-19 vaccine 
      • For most people at least 5 months after the final dose in the primary series
    • 2nd booster of either Pfizer or Moderna COVID-19 vaccine 
      • For adults ages 50 years and older at least 4 months after the 1st booster 
• For individuals who received a primary series of J&J, they are up to date “immediately after getting all boosters recommended for”: 
  • Boosters: 
    • 1 booster, preferably of either Pfizer or Moderna COVID-19 vaccine
      • For most people at least 2 months after a J&J/Janssen COVID-19 vaccine 
    • 2nd booster of either Pfizer or Moderna COVID-19 vaccine 
      • • For adults ages 50 years and older at least 4 months after the 1st booster

In addition, “people ages 18 through 49 years who received a J&J/Janssen COVID-19 vaccine for both their primary dose and booster can choose to get a 2nd booster of either Pfizer-BioNTech or Moderna COVID-19 vaccine at least 4 months after their 1st booster. The 2nd booster is not required to be considered up to date for people ages 18 through 49 years who got a J&J/Janssen COVID-19 vaccine for both their primary dose and 1st booster.” 

• For individuals who received a primary series of Novavax (2 doses of Novavax), they are up to date “2 weeks after final dose in primary series, since a booster is not recommended at this time for anyone who has completed the Novavax COVID-19 primary series.” 

If a person does not meet these requirements, regardless of the person’s age, the person is NOT up to date.

Head Start encourages all employees to review the CDC’s reference material titled “At-A-Glance COVID-19 Vaccination Schedule (Updated August, 2022) to “to determine how many total COVID-19 vaccine doses are recommended based on primary series product, age, and immune status.” The reference material is available here: https://www.cdc.gov/vaccines/covid-19/clinical-considerations/covid-19-vaccines-us.html. Head Start also encourages employees to check with their medical provider(s) if they have any questions related to the COVID-19 vaccines and boosters. * * * 

Procedure

1. Employees must provide proof of vaccination according to the Timeline Chart (below). “Proof of vaccination” means documentation provided by a tribal, federal, state, or local government, or a healthcare provider, that includes an individual’s name, date of birth, type of COVID-19 vaccination given, date or dates given, depending on whether it is a one-dose or two-dose vaccine, and the name/location of the healthcare provider or site where the vaccine was administered. Documentation may include but is not limited to a COVID-19 vaccination record card or a copy or digital picture of the vaccination record card, or a printout from the Oregon Health Authority’s immunization registry. 
2. In the event that despite the employee’s best efforts, the employee cannot receive the additional booster(s) before the required due date, the employee must notify Tim Rochholz, Director of Human Resources and Val Haynes, RN, BSN, and Health and Safety Consultant immediately.  

New hires will be required to provide proof of vaccination before their first day of employment. New hires will not be permitted to begin working in any capacity until they are up to date on their vaccinations against COVID-19. 

Head Start will provide information and instructions about this process and make it available on its webpage(s). If employees receive the vaccine during work hours, they should record their time as work time and should notify their supervisors.  

Exemptions

Employees may request an exemption from the COVDI-19 vaccination requirements for medical or religious reasons, including for reasons provided in Oregon and federal law, by the following process:

• Employees who cannot be vaccinated for a medical reason may seek a medical exemption. “Medical Exception” means that an individual has a physical or mental impairment that prevents the individual from receiving a COVID-19 vaccination. The process to request a medical exemption will require the employee to provide supporting documentation from a healthcare provider.
• Employees may seek a religious exception. “Religious Exception” means that an individual has a sincerely held religious belief that prevents the individual from receiving a COVID-19 vaccination. The process to request a religious exception will require the employee to provide a statement describing the way in which the vaccination requirement conflicts with the religious observance, practice, or belief of the individual.

To request an exemption, employees must complete a COVID-19 Vaccine Medical Exception Request Form or a COVID-19 Religious Exception Request Form and submit it to the Human Resources Department. Exception requests will be reviewed on a case-by-case basis.

• * * Exemption requests must be submitted by the dates in the Timeline Chart.  
• In light of the potential availability of a bivalent and/or multi-variant COVID-19 vaccine booster in Fall 2022, employees will be provided an extension until November 4, 2022; Employees need to be in contact with their medical provider and follows their provider(s)’s instructions. * * * 

Reasonable Accommodations

Per OHA guidance, schools that grant medical or religious exceptions must take “reasonable steps to ensure that unvaccinated teachers, school staff and volunteers are protected from contracting and spreading COVID-19.” Reasonable steps may include without limitation weekly testing, a fitted n95 mask, additional distancing, and a facemask with a face shield, a remote workspace, or other steps. In some circumstances, “reasonable steps” may also include unpaid leave.

Consequences

Per OHA rule, after October 18, 2021, Head Start employees and volunteers may not teach, work, provide care, learn, study, assist, observe, or volunteer for Head Start unless they are fully vaccinated or have provided documentation of a medical or religious exception. Head Start may not employ, contract with, or accept the volunteer services of staff or volunteers who are teaching, working, providing care, learning, studying, assisting, observing, or volunteering at Head Start unless the employees or volunteers are fully vaccinated against COVID-19 or have a documented medical or religious exception.

Employees who are not up to date with their vaccinations against COVID-19, and who have not been granted an exemption by the deadlines above may be subject to disciplinary and/or corrective action, up to and including possible dismissal from employment. Employees who are found to have falsified information related to their COVID-19 vaccination status or eligibility for an exemption may be subject to disciplinary and/or corrective action, up to and including possible dismissal from employment.

Head Start will work to assist our community members experiencing barriers to receiving vaccinations.

All employees are expected to carefully review Head Start’s policies. It is important that Head Start employees adhere to these policies so that we can work together to respond to this ongoing challenge and continue to provide excellent service to the children and families in our community. 

If you have any questions regarding these policies or request forms, please contact the Human Resources Department for more information. 

Anti Retaliation

Head Start prohibits retaliation against any employee, student, or volunteer for filing a good-faith complaint regarding conduct in violation of this policy. Head Start will not tolerate retaliation for raising a good-faith concern, for providing information related to a concern, or for otherwise cooperating in good faith in an investigation of a reported violation of this policy. Any employee who retaliates against anyone involved in an investigation is subject to disciplinary and/or corrective action, up to and including termination. Any retaliation by a student or volunteer will be addressed in accordance with Head Start policies and procedures.

Head Start will adjust this policy if appropriate and necessary in light of changing circumstances and experience. The most updated policy will be available.

Created August 2021

Policy Council approved August 2021

Updated: September 2021. August 2022