NY Healthcare Institutions Need to Vaccinate For Common Flu and H1N1
It’s difficult to pick up a newspaper or turn on the evening news without being confronted by the increased societal awareness of the dangers associated with common flu and H1N1 virus (Swine Flu) infections this year. Alarming new facts about common flu and the H1N1 virus appear in the news every week. Indeed the Centers for Disease Control and Prevention (CDC) issued a public statement this past week announcing the increased risk of H1N1 infection to pregnant women, citing evidence that 28 of 100 pregnant women admitted to intensive care units for H1N1 infection in the US this year have died. The World Health Organization (WHO) recently reported that of the +300,000 laboratory-confirmed cases of H1N1 infection in 191 countries this year, almost 4,000 resulted in the death of the infected individuals. Incredibly, some still debate the semantics of whether the spread of H1N1 virus constitutes a global pandemic and others even allege that this is media-manufactured panic attack.
Meanwhile the New York State Department of Health is taking prudent, aggressive measures to suppress viral outbreaks in what are arguably our most vulnerable locales: healthcare institutions. A letter issued by the State of New York Department of Health (DOH) on August 26, 2009 to Healthcare administrators calls attention to a new “emergency regulation” regarding influenza vaccinations (Part 66, Subpart 66-3 Health Care Facility Personnel – Influenza Vaccine Requirements). The letter calls on healthcare institutions to require common influenza vaccinations for personnel who have direct contact with patients and for personnel whose activities within a healthcare organization could theoretically pose a risk of viral transmission to patients. Additionally, the same employees must also receive the novel H1N1 vaccine if such a vaccine becomes available. All of these personnel must be vaccinated by November 30th, 2009. The DOH confidently states that this mandate was established in the interest of reducing nosocomial infection and furnishing a healthy workforce of professional caregivers this coming flu season.
It will be a challenge for healthcare administrators to comply with this new mandate. The logistics of vaccinating a large workforce are difficult enough, but administrators must also address additional physiological, societal and economic complications, including:
• Accommodating employees with allergies to vaccines.
• Addressing employees who have moral/ethical/religious objection to immunization/vaccination.
• Policing and documenting the vaccination of a workforce of outside contractors/vendors present in healthcare organizations.
The DOH suggests that each healthcare institution work closely with its Human Resources department to navigate the above-mentioned complications. For situations where individuals cannot receive vaccination for medical reasons, the DOH invites administrators to seek guidance from its website. A “frequently asked questions” attachment to the DOH’s letter explains that there is “no legal requirement to allow religious exemptions to influenza vaccination”. However, the DOH stops short of recommending that employees with objections to vaccination should be terminated, and instead suggests that those employees might be reassigned to non-covered duties. Contractors and vendors who supply services to healthcare institutions should take note of this regulation and address the matter with their healthcare clients to evaluate the applicability of this mandate to their own activities. It is clear that many contractors and vendors will have to comply with the new regulation, particularly if those contractors frequently access patient care areas.
You can read the State of New York DOH’s letter and the regulations relevant to this important new vaccination mandate by clicking on the link below.
State of New York Department of Health: Title Subpart 66-3 – Health Care facility Personnel – influenza vaccination requirements