Imagine! Employee Vaccination Policy Information
Imagine!'s Vaccine Policy
- Effective September 1, 2021, all Imagine! employees must be fully vaccinated against COVID-19.
- Employees who cannot receive the vaccination due to a medical exemption or a religious exemption can begin engaging in the Americans with Disabilities Act (ADA) interactive process to seek accommodations for this employment requirement by September 1, 2021.
- We will work with each employee who is unable to comply with the policy after September 1, 2021, to explore options, which may include an unpaid leave of absense. We are not, at this time, prepared to commit to termination of employees who are unable to comply because we intend to work with each employee through their their individual circumstances.
How Did We Come To This Decision?
Through internal discussion for many months with the Board of Directors, staff leadership, review of employee survey input, consulting with employment law, and monitoring the science and outcomes of vaccination deployment, we have determined that this policy reflects Imagine!'s mission, our values, and our guiding principles.
Safety for all that is backed by science and law
Over 600,000 people have died from COVID-19 and it is now the third leading cause of death in the United States. There is strong evidence showing that the risks of infection and transmission of COVID-19 are greatly reduced in the vaccination population. Healthy people able to receive the vaccine provide critical protections for those who cannot due to medical and/or religious reasons. We need a healthy workforce to provide safe and terrific services to people who depend on us.
Additionally, under Equal Employment Laws, including the Americans with Disabilities Act and Occupational Safety and Health Administration laws, employers have a responsibility to their employees to ensure their safety and well-being while at work.
This allows employers to mitigate anything that might be a "direct threat to the health or safety of the employee or others." In March, 2020, the EEOC* determined that the risk of contracting COVID-19 constitues a "direct threat." This determination enabled employers to take a variety of measures to ensure that their employees remain safe - including remote work, use of PPE, and now, up to and including requiring the vaccination.
* The Equal Employment Opportunity Commission (EEOC) is responsible to enforcement of Equal Employment Laws, including the ADA and Title VII of the Civil Rights Act. The EEOC has long held that employers can require vaccinations.
Service delivery with the least restrictions
This pandemic has disproportionately impacted the people we serve. Impacts include: heightened isolation due to increased risk of significant complications if COVID-19 were contracted; difficulties accessing society/services/education; intolerance of mask mandates; and lack of understanding of the virus and the vaccine. A fully vaccinated workforce will give individuals in services and their family members peace of mind that service delivery will be as safe as possible for their loved ones and free of the restrictions and barriers they have had to tolerate for 15 months.
Equity
Our policies must be equitable across the employee population. We shall strive to avoid inequitable expectations on different job positions at Imagine!. We have the opportunity to create a policy that includes everyone in our workforce. Requiring the vaccine for some employees and not all would perpetuate inequities we saw throughout the pandemic.
Freedom of Movement and Ease of Communication
The vaccine allows us to safely interact in person with one another again. Fully vaccinated people can also safely remove their masks, allowing us to see each others' smiles again! Not wearing masks enables full and more effective communication with the people we serve, including those who do not communicate verbally. Unmasked service delivery allows us to better implement speech therapy plans, express feelings for those who may not understand different voice connotations, and it allows all employees to be identified more easily by those we serve.
What Are My Next Steps?
I am vaccinated:
Provide proof of your vaccination card by emailing a copy to HR@imaginecolorado.org before September 1, 2021. Please use this email address only, and use this subject header: lastnamevaccinationcard
I am not vaccinated and plan to be:
Make sure to find a location in which you can receive your first and second (if applicable) vaccination in a timely manner (prior to September 1, 2021). Once you have proof of vaccination, email it to HR@imaginecolorado.org. Please use this email address only, and use this subject header: lastnamevaccinationcard
I am not vaccinated and plan to apply for an exemption through HR and ADA:
Reach out to your HR Business Partner as soon as possible to obtain the proper paperwork and engage in the ADA process. See below for more details.
I am not vaccinated and do not plan to be:
We encourage you to notify your HR Business Partner of your decision. We will work with each employee who is unable to comply with the policy after September 1, 2021, to explore options, which may include an unpaid leave of absence, until they are able to discuss the matter with Human Resources to determine the appropriate course of action.
Reporting Vaccination Status to Imagine!
- Employees should email their vaccination record (scanned or photo copy) to HR@imaginecolorado.org. Please use this email only, and use this subject header: lastnamevaccinationcard
- This is the ONLY email address that should be used to report vaccination status. Because vaccination cards contain personal health information (date of birth) that supervisors do not typically have access to, only Human Resources should receive copies of vaccination records.
- HR will maintain records in a secure manner
- Records can be sent anytime starting June 24 BUT masks are still required through June 30
- Effective July 1, fully vaccinated employees with records with HR can be unmasked.
- There will be processing time for entering vaccination information into DayForce. Once the information is entered, Human Resources will provide regular reports to supervisors through September.
- In the meantime, the honor system at all locations except staffed residential sites will be used to trust that employees who are unmasked have turned in their vaccination records. Those who do not respect this policy may face disciplinary action.
- If a supervisor has a concern that someone is not following the policy, those concerns should directo the Human Resources.
- Keep in mind that all resources will be dedicated to entering the vaccination records as quickly as possible.
Americans with Disabilities Act Interactive Process
Employees who have a medical condition or a religious reason that prevents them from receiving the COVID-19 vaccination shall contact Human Resources to request an accommodation under the ADA. This process is handled through Human Resources only.
Medical Exemption
A doctor will complete required accommodation paperwork (provided by Human Resources) stating that the employee should be exempt from the COVID-19 vaccine.
Religious Exemption
The employee shall turn in the required accommodation paperwork attesting that their religious beliefs prevent them from receiving the COVID-19 vaccine.
Possible Accommodations
If an employee is given an exemption from receiving the COVID-19 vaccine, the employee must still be able to complete the essential functions of their job with the accommodation for the COVID-19 vaccine. Possible accommodations include (but are not limited to):
- Wearing a mask
- Having a separation barrier of some kind between work stations
- Working remotely
Short Term Plans
- Fully vaccinated staff can provide in-person services unmasked with proof of vaccination status. Update - August 4, 2021. Imagine! employees are required to wear masks at all times when in Imagine! buildings.
- Fully vaccinated participants can attend in-person services unmasked effective June 16. Unvaccinated participants are required to wear masks.
- Children (17 and under) are not required to wear masks regardless of vaccination status.
- Fully vaccinated staff can be unmasked with proof of vaccination status. Update - August 4, 2021. Imagine! employees are required to wear masks at all times when in Imagine! buildings.
- Fully vaccinated staff can be unmasked in the office effective when they submit their vaccination card to HR. Update - August 4, 2021. Imagine! employees are required to wear masks at all times when in Imagine! buildings.
- Fully vaccinated staff can be unmasked in the office effective when they submit their vaccination card to HR. Update - August 4, 2021. Imagine! employees are required to wear masks at all times when in Imagine! buildings.
- Mask mandate, regardless of vaccination status, remains for visitors to Imagine! property (aside from Group Homes) and volunteers until September 1, 2021.
- Unvaccinated, or partially vaccinated employees, must continue to wear masks.
- Dixon and Coal Creek administration buildings will remain closed to the public until September 1, 2021. We will resume typical public hours at that point. Update - August 4, 2021. Opening adminstrative buildings will be delayed until further notice.
- Effective immediately we will inform applicants of our vaccination policy and requirement to comply.
FAQs
Please explain the legal thinking behind this policy.
The Equal Employment Opportunity Commission determined in March of 2020 that the risk of contracting COVID-19 constitutes a "direct threat." This allows Imagine! to put a variety of procedures in place to keep employees safe, up to and now including, vaccination. Since the development of the polio vaccination, employers have been able to mandate vaccination as a term of employment.
Will individuals in services be required to get the vaccine in order to receive services?
No. Unvaccinated individuals will be required to wear masks for now. As community transmission continues to trend down, we may adjust this requirement. For now, our vaccinated workforce will help protect unvaccinated individuals in services. This requirement includes individuals in services who are also employees of Imagine!. The requirement affects their employment, not their access to services.
If I decide not to get vaccinated, and I don't qualify for an exemption, will I be fired on September 2, 2021?
Human Resources and department leadership will work with employees who are unable to comply with this policy including discussion of placing the employee on unpaid leave of absence. Our goal is to minimize service disruption as much as possible during this transition.
Are other CCBs or providers requiring the vaccine?
At this time, we are not aware of other organizations in this industry moving forward with this requirement. We are aware of several that are considering it. We are aware of Colorado-based organizations in other industries that are requiring it as well as providers of I/DD services outside of Colorado that are requiring it.
The vaccine isn't fully approved by the FDA — it has Emergency Use Authorization only. Did you consider this?
Yes. The difference between the EUA and regular FDA approval is that manufacturing begins at the same time as testing. Full FDA authorization requires six months of data and all three manufacturers are close to this. Pfizer and Moderna recently applied for full authorization and is expected to receive it.
How will you manage employees feeling coerced to get the vaccine?
Imagine! has no intention of coercing employees into getting the vaccine. If this new policy, or any Imagine! policy, mission, or value statement is not congruent with an employee's personal choices or values, Imagine! understands and respects that this may lead to the employee's separation from the company.
Most people who get COVID-19 don't experience major symptoms. It seems extreme to require a vaccination for a virus that most people experienced as a cold or a bad flu.
Over 600,000 people in the United States have died from COVID-19 and millions of survivors are experiencing long-term effects, including people who had mild symptoms. These long-term effects include fatigue, brain fog, headaches, and other debilitating symptoms. The COVID-19 pandemic literally shut down the world for nearly a year and continues to ravage some parts of this country and many other countries across our planet. Variants that we don't fully understand continue to emerge. Imagine! will do its part to support public health efforts to end this pandemic.
For new hires, what is considered a reasonsable timeframe to comply with this new policy?
New hires will have 60 days to comply with our vaccination policy.
If an employee is placed on unpaid leave of absence for not complying with the policy, will they still have access to benefits? Will they be able to use vacation hours?
Imagine! will provide access to benefits for up to two months for staff on an unpaid leave of absence. Employees will be responsible for the cost sharing portion of their benefits. It will be up to the employee if they want to use accrued vacation time (but not acrrued sick time) while on unpaid leave of absence.
If I am placed on a leave of absence, is Imagine! required to hold my position open for me?
No, your position is only protected under ADA and FMLA.
Where can I go to get vaccinated?
This link will help you find the most convenient place for you to receive your vaccination: https://covid19.colorado.gov/vaccine/where-you-can-get-vaccinated
Where can I obtain proof of my vaccination if I lost my card?
Contact the provider in which you received the vaccination or reach out to Colorado Immunization Information System (CIIS) help desk at 303-692-2437 or their verification site: https://ciis.state.co.us/public/Application/PublicPortal