POLICY #4300

 

NORWICH FREE ACADEMY

COVID-19 VACCINATION AND TESTING POLICY

 

On September 10, 2021, Governor Lamont issued Executive Order No. 13G (“Protection of Public Health and Safety During COVID-19 Pandemic – Vaccination Requirements for State Employees, School Staff, and Child Care Workers”) requiring all covered workers in a public or non-public pre-K through grade 12 school system to  be at least partially vaccinated against COVID-19 by September 27, 2021, and if not fully vaccinated on or after that date, to submit to weekly COVID-19 testing. Executive Order No. 13G further requires school boards to implement policies containing certain requirements set forth in the Order as applicable to the schools or school systems operated by such boards. Accordingly, the Norwich Free Academy Board of Trustees (the “Board”) adopts this policy as applicable to the Norwich Free Academy (the “District”) and the schools that are a part of the District.

A.        DEFINITIONS:

Contractor means any person or business entity, including a vendor of support services or subcontractor, that provides personnel who function as District covered workers, except any contractor or employee of an outside vendor who visits the school district only to provide one-time or limited-duration repairs, services, or construction.

Covered Worker means all employees, both full-time and part-time, contract workers, providers, assistants, substitutes, and other individuals working in the District, including individuals providing operational or custodial services or administrative support or any person whose job duties require them to make regular or frequent visits to the school district. Covered worker does not include a contract worker or employee of an outside vendor who visits the school district only to provide one-time or limited-duration repairs, services, or construction, or a volunteer.

COVID-19 is a respiratory disease caused by SARS-CoV-2, a new coronavirus discovered in 2019. The virus is thought to spread mainly from person to person through respiratory droplets produced when an infected person coughs, sneezes, or talks.

Fully Vaccinated means at least 14 days have elapsed since the covered worker has received the final dose of a vaccine approved for use against COVID-19 by the U.S. Food and Drug Administration (“FDA”), or as otherwise defined by the Centers for Disease Control and Prevention (“CDC”). In general, people are considered fully vaccinated at least 14 days after their second dose in a two-dose series, such as the Pfizer or Moderna vaccines, or at least 14 days after a single-dose vaccine such as Johnson & Johnson’s Janssen vaccine.

B.        COVID-19 VACCINATION REQUIREMENT:

(1)   Covered Workers Hired By the Board or Working in the District Before September 27, 2021: On or before September 27, 2021, all covered workers hired by the Board or working in the District before that date must:

 

(a)   Be fully vaccinated against COVID-19;

(b)   Have received the first dose and have either received a second dose or have an appointment for a second dose in a two-dose series vaccination, such as Pfizer or Moderna vaccines, or have received a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine;

(c)   Be exempt from the vaccination requirement because a physician, physician’s assistant (“PA”), or advanced practice registered nurse (“APRN”) determined that the administration of a COVID-19 vaccine is likely to be detrimental to the covered worker’s health, or the covered worker objects to vaccination on the basis of a sincerely held religious or spiritual belief, and the covered worker is able to perform his or her essential job functions with a reasonable accommodation that is not an undue burden on the Board; or

(d)   As an alternative to vaccination, and regardless of whether the covered worker has a medical or religious exemption, comply with the testing requirements contained in this policy and any other applicable safety precautions of the Board and/or the District.

 

(2)  Prospective Employees: On and after September 27, 2021, a covered worker not employed by the Board or working in the District as of that date shall not be extended an offer of employment, and the District shall not enter into a contract for the services of a covered worker, unless the covered worker:

 

(a)   Is fully vaccinated against COVID-19;

(b)  Has received the first dose and has either received a second dose or has an appointment for a second dose in a two-dose series vaccination, such as Pfizer or Moderna vaccines, or has received a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine; or

(c)   Is exempt from the vaccination requirement because a physician, physician’s assistant (“PA”), or advanced practice registered nurse (“APRN”) determined that the administration of a COVID-19 vaccine is likely to be detrimental to the covered worker’s health, or the covered worker objects to vaccination on the basis of a sincerely held religious or spiritual belief, and the covered worker is able to perform his or her essential job functions with a reasonable accommodation that is not an undue burden on the Board.

C.        COVID-19 VACCINATION VERIFICATION REQUIREMENT:

By September 27, 2021, covered workers of the Board employed by the Board or working in the District before September 27, 2021 are required to provide proof of COVID-19 vaccination status to the Board unless otherwise exempt from the vaccine requirement as permitted by law. Covered workers of the Board employed by the Board or working in the District on or after September 27, 2021 are required to provide proof of COVID-19 vaccination status to the District prior to becoming employed by the Board or working in the District unless otherwise exempt from the vaccine requirement as permitted by law.

 

(1)   Vaccination Verification: The District shall authenticate the vaccination status of covered workers, maintain documentation of vaccination or exemption of such covered workers, and report compliance with Executive Order No. 13G, in a form and manner directed by the Department of Public Health.

 

(2)  Acceptable Proof of Vaccination: To provide proof of COVID-19 vaccination, a covered worker must submit one of the following:

 

(a)   A valid CDC COVID-19 Vaccination Record Card or photo of the Vaccination Record Card. The card must contain the name and date of birth of the covered worker, the manufacturer of the COVID-19 vaccine that was administered, and the date(s) on which the vaccine was administered.

(b)  A record from the covered worker’s vaccine provider indicating the name and date of birth of the covered worker, the manufacturer of the COVID-19 vaccine that was administered, and the date(s) on which the vaccine was administered (“Provider Vaccination Record”). Covered workers may contact their vaccination provider to request a copy or log into the patient portal for that provider.

(c)   A certificate from the Vaccine Administration Management System (“VAMS”) if the individual received vaccination through the VAMS system (“VAMS Certificate”). The VAMS Certificate must contain the name and date of birth of the covered worker, the manufacturer of the COVID-19 vaccine that was administered, and the date(s) on which the vaccine was administered.

(d)  A copy of the covered worker’s official immunization record from the Connecticut Immunization Information System, CT WiZ. Valid CT WiZ immunization records contain the name and date of birth of the covered worker, the manufacturer of the COVID-19 vaccine that was administered, and the date(s) on which the vaccine was administered.

 

Covered workers shall not include any additional medical or genetic information with proof of COVID-19 vaccination.

 

(3)  Declaration of Authenticity: Covered workers who have submitted a copy of a vaccination record as proof of vaccination shall complete and sign a declaration as to the authenticity of their proof of vaccination. Proof of vaccination will not be deemed valid unless accompanied by the covered worker’s signed declaration. Personal attestation alone will not be accepted as an acceptable form of proof of vaccination.

 

(4)  Submission of COVID-19 Vaccine Documentation: All covered workers who are fully or partially vaccinated must submit proof of COVID-19 vaccination and a completed declaration form to the following:

Amy Tavares

Medical Center Supervisor

tavaresa@nfaschool.org

ph:  (860) 425-5552

fax:  (860) 889-3291

 

Covered workers employed by the Board or working in the District prior to September 27, 2021 shall submit such documentation by September 27, 2021.

 

D.        EXEMPTION FROM COVID-19 VACCINATION REQUIREMENT:

 

Covered workers may receive an exemption from the COVID-19 vaccination requirement for medical or religious/spiritual belief reasons as described below:

 

(1)   Medical Exemption: Covered workers may receive a medical exemption because a physician, physician’s assistant (“PA”), or advanced practice registered nurse (“APRN”) determined that the administration of a COVID-19 vaccine is likely to be detrimental to the covered worker’s health and the covered worker is able to perform his or her essential job functions with a reasonable accommodation that is not an undue burden on the District.

 

(2)  Religious/Spiritual Belief Exemption: Covered workers may receive a religious/spiritual belief exemption because the covered worker objects to vaccination on the basis of a sincerely held religious or spiritual belief and the covered worker is able to perform his or her essential job functions with a reasonable accommodation that is not an undue burden on the District.

Covered workers who seek a medical or religious/spiritual belief exemption to the vaccine requirement must apply for the exemption and must provide appropriate supporting documentation upon the District’s request. To submit a request for a medical or religious/spiritual belief exemption, covered workers must complete the appropriate District form(s) send their request to the below:

Amy Tavares

Medical Center Supervisor

tavaresa@nfaschool.org

ph:  (860) 425-5552

fax:  (860) 889-3291

 

Covered workers employed by the Board or working in the District prior to September 27, 2021 shall send their request by September 27, 2021. Each exemption request will be considered on an individualized, case-by-case basis. All exemptions will be considered pending until the covered worker has received written notice of an approval or denial. Covered workers granted an exemption are required to comply with the testing requirements of Executive Order No. 13G and this policy.

E.        REFUSAL TO RECEIVE COVID-19 VACCINATION:

Covered workers then-presently employed by the Board or working in the District before September 27, 2021, and who did not apply for or applied and did not receive a medical or religious/spiritual belief exemption from the COVID-19 vaccination requirement under Executive Order No. 13G and who are not fully vaccinated, regardless of reason, shall notify the District by sending written notice to the below by September 27, 2021:

Amy Tavares

Medical Center Supervisor

tavaresa@nfaschool.org

ph:  (860) 425-5552

fax:  (860) 889-3291

 

In addition, covered workers entering the workplace who are not fully vaccinated against COVID-19 must follow any additional safety precautions imposed by the District, which may include, but are not limited to, wearing a face covering, working at a social distance from coworkers or students, working a modified shift, accepting a reassignment, quarantining, and/or isolating.

 

F.        WEEKLY COVID-19 TESTING VERIFICATION OF COVERED WORKERS NOT FULLY VACCINATED:

 

(1)   Testing Requirement: Beginning September 27, 2021, covered workers who are either not fully vaccinated or have not provided proof of full vaccination must submit to COVID-19 testing one time per week on an ongoing basis until fully vaccinated and provide adequate proof of the test results on a weekly basis (i.e., at least one test every seven (7) days) in a form and manner directed by the Department of Public Health unless they can provide documented proof that they have tested positive for, or been diagnosed with, COVID-19 infection in the prior ninety (90) days and have been granted a temporary waiver from SARS-CoV-2 testing. To comply with the testing requirement, testing must be either PCR or antigen SARS-CoV-2 tests and must be administered and reported by a state licensed clinical laboratory, pharmacy-based testing provider, or other healthcare provider facility with a current Clinical Laboratory Improvement Amendments (CLIA) waiver. Only test results submitted to the District within 72 hours of the test administration date will be deemed compliant with the testing requirement. Test result reports should include the name and location of the testing laboratory or provider facility performing the test, the name of the person tested, the date the sample was collected, and the test result. Home-based testing and results obtained outside of a facility of the type indicated above are not considered adequate proof of a SARS-CoV-2 test for the purposes of complying with Executive Order No. 13G and this policy. Processing delays with vaccine providers, VAMS, web-based applications, laboratories, medical providers, or state agencies will not excuse compliance with Executive Order No. 13G and this policy.

 

(2)  Submission of Testing Verification: Covered workers must provide adequate proof of the test results on a weekly basis (i.e., at least one test every seven (7) days) to:

 

Amy Tavares

Medical Center Supervisor

tavaresa@nfaschool.org

ph:  (860) 425-5552

fax:  (860) 889-3291

 

Covered workers shall not include any additional medical or genetic information with COVID-19 test results.

 

(3)  Negative Test Results Required: Covered workers required to participate in weekly testing in lieu of vaccination are required to submit at least one SARS-CoV-2 test result every seven (7) days and comply with all other provisions of Executive Order No. 13G and this policy in order to retain access to on-site work. Covered workers shall not be permitted, and shall not attempt, to be present on District premises or at District-sponsored activities unless the most recent test result provided is “negative” or indicates that virus material is “not detected.” Results provided as “inconclusive” are not considered negative results and as such require retesting. If a covered worker receives an inconclusive result and cannot be retested and provide a negative result within seven (7) days of their last negative test, then that covered worker shall be excluded from, and shall not attend, on-site work until they can provide a negative test result.

 

(4)  Temporary Testing Waivers: Covered workers who wish to request a temporary waiver from SARS-CoV-2 testing on the basis of having had COVID-19 within the prior ninety (90) days must submit a Temporary Waiver request completed and signed by their healthcare provider, using the submission format and process for submitting test results provided above. Any covered worker granted a temporary waiver from SARS-CoV-2 testing must return to regular weekly testing after the expiration date indicated on the waiver form if they are not fully vaccinated by that date.

 

(5)  Additional Safety: In addition, the above covered workers entering the workplace who are not fully vaccinated against COVID-19 must follow any additional safety precautions imposed by the District, which may include, but are not limited to, wearing a face covering, working at a social distance from coworkers or students, working a modified shift, accepting a reassignment, quarantining, and/or isolating.

 

G.        CONTRACTOR REQUIREMENTS:

 

On and after September 27, 2021, any and all contractors of the District shall be required to authenticate the vaccination status of its contract workers as required by Executive Order No. 13G, maintain documentation of vaccination or exemption of such contract workers, and provide such documentation upon request and report compliance to the District on September 28, 2021 and thereafter upon request in a form and manner directed by the Department of Public Health. Further, on and after September 27, 2021, any and all contractors of the District shall implement a policy that requires its contract workers who have not demonstrated proof of full vaccination to submit to COVID-19 testing not less than once per week on an ongoing basis until fully vaccinated and provide adequate proof of the results of the testing on a weekly basis to the District in a form and manner prescribed by the Department of Public Health. Additionally, any and all contractors of the District shall positively affirm that they and their contract workers are in compliance with the provisions of Executive Order No. 13G prior to entering District premises.

 

H.       CONFIDENTIALITY:

 

All records of vaccinations, weekly COVID-19 tests, exemptions, and any other information or documentation submitted, collected, or maintained regarding a covered worker pursuant to Executive Order No. 13G shall be kept confidential as required by law.  

The District shall treat all employee-provided medical information as confidential medical records, separate from the employee’s personnel file. If necessary, medical information may be shared in limited circumstances and subject to appropriate controls to those persons who have a legitimate need to know including, but not limited to, District administration, first aid and safety personnel, and government officials, as required by law or other relevant guidance.

I.         VIOLATIONS AND ENFORCEMENT:

A covered worker who fails to comply with the requirements of this policy shall not be allowed on the premises of the District or at District-sponsored activities until the covered worker provides adequate proof of compliance or without prior written authorization of the District. Violations of this policy may result in appropriate disciplinary action, up to and including termination. Violations of this policy by covered workers can result in findings that the Board and/or the District has violated the requirements of Executive Order No. 13G or other laws or regulations which could subject the Board to legal penalties, including, but not limited to, loss of state-provided educational funding.

Legal Reference:       CT. Executive Order No. 13D, August 19, 2021

                                    CT. Executive Order No. 13G, September 10, 2021

Connecticut General Statutes  

§ 10-145 Certificate necessary to employment. Forfeiture for noncompliance. Substitute teachers.

                                    Implementation Guidance for Executive Order 13G: Vaccination Mandate for Individuals Working for State Facilities, State Hospitals, Public and Non-Public PreK-12 Schools, and Child Care Facilities, Connecticut State Department of Public Health, Sep. 17, 2021.

Policy Adopted:         September 21, 2021

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