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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 2021-2022 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.

This requirement applies equally to those who have previously been diagnosed with COVID-19. According to the OHA:

The Delta variant causes more infections and spreads faster than earlier forms of the virus that causes COVID-19. It might cause more severe illness than previous strains in unvaccinated people. The risk of severe illness and death from COVID-19 outweighs the benefit of natural immunity. Given the variability in immune response, a lot of people who get infected naturally can get reinfected again, in sometimes as short as a few months. People who have had the illness should still be vaccinated for the best possible protection Employees

No later than September 3, 2021, employees will identify the maker of the COVID-19 vaccine they received and the date(s) of their vaccination(s) to their supervisor. In the event that the employee elects to receive one of the two-dose vaccines, and cannot, despite the employee’s best efforts, receive both doses of the two-dose COVID-19 vaccine before September 10, 2021, the employee must notify their supervisor immediately.

New hires will be required to provide the identity of the maker of the COVID-19 vaccine they received and the date(s) of their vaccination(s) to Sally Pope, Benefits Specialist before their first day of employment. New hires will not be permitted to begin working in any capacity until fully vaccinated.

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.

Any vaccine authorized for use in the United States is acceptable—namely Pfizer-BioNTech, Moderna, and Johnson & Johnson/Janssen. An individual must be “fully vaccinated” by the schedules set forth below to be at the Head Start center. In general, people are considered fully vaccinated

  • Two weeks after their second dose in a 2-dose series, such as the Pfizer or Moderna vaccine, or
  • Two weeks after a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine.

If a person does not meet these requirements, regardless of the person’s age, the person is NOT fully vaccinated.

This means that at least two weeks must have passed before the deadlines below.

Procedure

  1. No later than September 3, 2021, employees and volunteers must provide proof of vaccination. “Proof of vaccination” means documentation provided by a tribal, federal, state, or local government, or a health care 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 health care 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 OHA’s immunization registry.
  2. In the event that the employee elects to receive one of the two-dose vaccines, and cannot, despite the employee’s best efforts, receive both doses of the two-dose COVID-19 vaccine before September 10, 2021, the employee must notify their supervisor and the Health and Safety Consultant immediately.
  3. 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 fully vaccinated.
  4. 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 September 3, 2021.

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 fully vaccinated 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.

Head Start will adjust this policy if appropriate and necessary in light of changing circumstances and experience. The most updated policy will be available at https://www.hsolc.org/policies-procedures/.

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