Mandatory COVID-19 Vaccination Policy
Mandatory COVID-19 Vaccination Policy
|Department||People and Culture|
|Creation Date||September 16, 2021|
|Approval Date||September 16, 2021|
|Effective Date||September 16, 2021|
This policy applies to all Michener employees, students, contractors and visitors working and studying at Michener.
The purpose of this Policy is to outline updated organizational expectations with regards to COVID-19 vaccination.
The purpose of this Policy is to outline updated organizational expectations with regards to COVID-19 vaccination of employees, students, contractors and visitors working and studying at Michener.
Michener is committed to protecting and promoting the health, safety and well being of its community, especially during the COVID-19 pandemic declared by the World Health Organization (“WHO”). Michener recognizes the importance of vaccination of Staff and Students to reduce the risk of serious infection and transmission of infection to co-workers and students and the potential for exposure in the community. This mandatory COVID-19 vaccination policy (the “Policy”) aims to protect Michener’s population including students, faculty, employees, staff, patients, contractors, and visitors. For the purposes of this Policy, “Staff” means all faculty, employees, contractors, staff, agency staff, and volunteers carrying on activities or other business at Michener. For the purposes of this Policy, “Students” means all individuals admitted and registered in a course of study at Michener
Michener is the only post-secondary institution in Canada that is solely dedicated to Applied Health Sciences. The majority of Michener’s students are placed in health care settings, including hospitals, where they often treat vulnerable and immunocompromised patients that are most impacted by the COVID-19 virus. In keeping with Michener’s mission, vision, and values, Michener aims to provide excellence in training Students to be preeminent applied health science practitioners. In doing so, Michener intends to utilize this Policy to model and support best practices in hospitals, many of which have now mandated full vaccination in accordance with Directive #6 issued by Ontario’s Chief Medical Officer of Health under section 77.7 of the Health Protection and Promotion Act on August 17, 2021 which aims to protect: healthcare workers, patients and healthcare system capacity.
In conjunction with this Policy that applies to Staff and Students, Michener is releasing a policy that will further clarify COVID-19 vaccination requirements and logistics for contractors (including people on contract, people employed by third parties such as employment agencies, people working in any businesses or entities operating on Michener’s premises) and visitors to Michener.
Currently, Michener is mandating that all new Staff and Students, unless they have an approved exemption pursuant to the Ontario Human Rights Code (“the Human Rights Code”), be fully vaccinated against COVID-19 prior to commencing their employment, work and/or studies with Michener.
In addition, Michener is mandating that its current Staff and Students must now be vaccinated against COVID-19 by no later than October 22, 2021, subject to the terms and conditions outlined below.
COVID-19 is an acute respiratory illness caused by the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). It may be characterized by fever, cough, shortness of breath, and several other symptoms. Asymptomatic infection is also possible. The risk of severe disease increases amongst those who remain unvaccinated, those who are of advanced age and those who have underlying medical conditions.
The World Health Organization (“WHO”) declared COVID-19 a pandemic virus on March 11, 2020. Since that time and as of the date of implementation of this Policy, there have been over 219,000,000 cases of COVID-19 infection worldwide and over 4.5 M deaths. In Ontario to date, there have been over 570,000 cases of COVID-19 infection and over 9500 deaths. In addition, the increasing prevalence of the Delta variant of concern globally and within Ontario, which has increased transmissibility and disease severity as compared to previous COVID-19 virus strains, presents an immediate risk to patients within UHN who are among the most acutely ill and medically complex in Ontario and indeed Canada, and therefore more susceptible to infection and severe outcomes from COVID-19.
In Ontario, it has been determined that unvaccinated individuals are 8 times more likely to get COVID-19 and will suffer more serious effects. Unvaccinated cases of COVID-19 have accounted for the majority (94.8%) of COVID-19 cases from December 14, 2020 to August 21, 2021. In addition, unvaccinated individuals have accounted for the majority (92.4%) of hospitalizations and deaths (92.1%) resulting from COVID-19.
Ontario’s Chief Medical Officer of Health (“CMOH”) has, therefore, opined that there exists or may exist an immediate risk to the health of persons anywhere in Ontario from COVID-19 and has accordingly directed Michener to develop, implement and ensure compliance with a COVID-19 vaccination policy, effective September 7, 2021. The CMOH issued instructions to all post-secondary institutions under subsection 2(2.1) of Schedule 1 and 4 of O. Reg. 364/20: Rules for Areas at Step 3 and the Roadmap Exit Step under the Reopening Ontario (A Flexible Response to COVID-19) Act (the “Instructions”). The Instructions aim to protect Staff, Students and the community from COVID-19 and to keep Students in school to the fullest extent possible in recognition that such objective is critical to Student learning, development and well-being. The Instructions recognize that vaccines provide the best protection against COVID-19 and conclude that by ensuring that Staff and Students are vaccinated, other community members will be protected by reducing the risk of COVID-19 transmission during an outbreak.
The Council of Medical Officers of Health, which represents the Medical Officers and Associate Medical Officers of Health in all 34 public health units across Ontario (the “Council”), has also strongly endorsed mandatory vaccination policies in all Ontario universities and colleges by letter dated August 24, 2021. The Council notes that the COVID-19 pandemic has greatly impacted post-secondary campuses and their surrounding communities and that the risk of COVID-19 has been highlighted by outbreaks among post-secondary students, both on and off campus. The Council also notes that, in Ontario, the age cohort with the highest cumulative number of cases has been amongst those who are students at post-secondary institutions, specifically aged 20-29. Full vaccination against COVID-19 is therefore strongly recommended by the Council for all individuals involved in any in-person activities on campus with the rare exception of those individuals who cannot be vaccinated due to permitted exemptions.
Michener requires that all Staff and Students receive the COVID-19 vaccine, unless they are exempt on the basis of medical or other grounds pursuant to the Human Rights Code
To facilitate this Policy, all Staff and Students will be required to provide one of the following:
- Proof of full vaccination against COVID-19 where, for the purposes of this Policy, “full vaccination” means having received all required doses of a COVID-19 vaccine approved by Health Canada; or
- Proof of a medical contraindication to vaccination as demonstrated by a written note provided by a physician or registered nurse in the extended class that sets out (i) a documented medical reason for Staff or Students not being fully vaccinated against COVID-19, and (ii) the effective time period for the medical reason (i.e., permanent or time-limited) (the “Documentation”); or
- A written request that another ground pursuant to the Human Rights Code applies which exempts an individual from getting the COVID-19 vaccine as demonstrated by evidence as required by Michener to determine that such a ground is in effect.
Staff who are unable to be vaccinated for medical reasons are required to provide the Documentation for review to UHN’s Health Services. Students who are unable to be vaccinated for medical reasons are required to provide the Documentation for review to Michener’s Health Services.
Staff and Students who are unable to be vaccinated due to other grounds pursuant to the Human Rights Code are required to provide the related documentation for review to Michener’s People and Culture Department.
Rapid Antigen Testing
If Staff and Students are deemed exempt following review of the Documentation or documentation related to request for human rights accommodation, they will be required to participate in the self-administered COVID-19 testing program and will be provided with rapid antigen testing kits that must be self-administered at home.
Similarly, until such time as fourteen days following Staff and Students being fully vaccinated, they will also be required to participate in the self-administered COVID-19 testing program. These Staff and Students will be required to provide a negative test within the previous 48 hours of coming on-site to Michener.
These rapid antigen tests are intended for regular testing of asymptomatic Staff and Students only and to identify those who may be infectious before coming on-site. The tests are not to be used by anyone with symptoms or who has a known exposure to someone with COVID-19.
Symptomatic and exposed Staff and Students must follow current guidelines to be tested in an assessment centre with a PCR test.
Staff who test positive on the rapid test must contact UHN Health Services and arrange for a confirmatory diagnostic PCR test at a Community Access Center. They will need to self-isolate at home pending the result of the confirmatory test. Students who test positive on the rapid test must contact Michener Health Services and arrange for a confirmatory diagnostic PCR test at a Community Access Center. They will need to self-isolate at home pending the result of the confirmatory test.
Rapid test kits can only be used by the Staff and Students who receive them. The rapid tests may not be given or sold to any other person.
All Staff and Students will be required to attest during their entry at Michener to screening that they either have been vaccinated or, where there is a medical contraindication to vaccination or other verified Human Rights Code exemption, have completed a rapid antigen test with a negative test result within the previous 48 hours when coming on-site.
Where Staff and Students have not provided proof of vaccination or obtained an approved exemption by Michener, Michener will provide information about the risks and benefits of the vaccine, including an educational program that addresses the following learning components:
- How COVID-19 vaccines work;
- Vaccine safety related to the development of the COVID-19 vaccines;
- Benefits of vaccination against COVID-19;
- Risks of not being vaccinated against COVID 19; and
- Possible side effects of COVID-19 vaccination.
Vaccination Information Collected, Maintained & Disclosed
In order to ensure compliance with this Policy and in compliance with the Instructions, the following statistical (non-identifiable) data (“the data”) will be collected, maintained and disclosed by UHN and Michener’s Health Services:
- Statistical (non-identifiable information) that includes:
- the number of Staff and Students that provided proof of being fully vaccinated against COVID-19;
- the number of Staff and Students that provided Documentation for not being fully vaccinated against COVID-19;
- the number of Staff and Students that provided documentation related to a ground pursuant to the Human Rights Code for not being fully vaccinated against COVID-19;
- the number of Staff and Students who obtained approved exemptions from Michener that have completed an educational session about the benefits of COVID-19 vaccination; and
- the total number of Staff and Students to whom the Instructions apply.
Upon request, Michener will disclose the statistical information to the Ministry of Colleges and Universities (“MCU”) and/or the Ministry of Health (“MOH”) (collectively for the purposes of this Policy, the “Ministry”). The Ministry may seek additional detail within the requested statistical information outlined above.
The Ministry may further disclose this statistical information and may make it publicly available. Michener will provide no identifying information to the Ministry in relation to this Policy; all statistical information will be provided in aggregate form.
UHN’s Health Services department is collecting and receiving information from Michener Staff and/or Students solely for the purpose of supporting Michener with the implementation and administration of this Policy further to Michener’s integration arrangement with UHN and such information will not be used by UHN for any other purpose.
In order to ensure compliance with this Policy and to ensure appropriate workforce and on-site class tracking (i.e. Staff or Student absences are properly managed and coded) and safe and appropriate class/education planning and scheduling is maintained, Supervisors and Program Heads may receive the following information, where necessary, on a confidential basis:
- Staff and Students who have tested positive for COVID-19 and are absent from the workplace and/or the on-site class.
- Staff and Students who have chosen not to be vaccinated and have obtained an approved exemption from Michener.
- Staff and Students who have chosen not to be vaccinated and will consequently be removed from the workplace and/or the on-site class.
Non-Compliance with the Policy
A failure of Staff and Students to disclose to UHN and/or Michener Health Services their vaccination status or to comply with the terms of this Policy and/or the COVID-19 rapid antigen testing program may result in discipline up to and including termination of employment, in the case of Staff, or withdrawal from one’s studies in accordance with the Michener’s Withdrawal Policy, in the case of Students, visit: withdrawal & tuition refund policy and procedure.
If Staff or Students are dishonest with regard to their participation in testing, testing result or vaccination status, they will be terminated with cause or be immediately and permanently withdrawn from their program of study in accordance with the Withdrawal Policy.
If a Staff member or Student without an approved exemption (medical or other ground pursuant to the Human Rights Code) refuses to be fully vaccinated after October 22, 2021 (without both vaccine shots), they will no longer be able to work or attend class on-site at Michener.
In order to have received both doses of a Health Canada-approved vaccine by October 22, 2021, Staff and Students should receive their first dose by no later than September 24, 2021. Until two weeks after receiving both doses of a Health Canada approved vaccine, Staff and Students must continue to comply with the requirements of the rapid antigen COVID-19 testing program.
Written requests for exemptions to the requirements of this Policy due to medical grounds should be submitted to UHN Health Service in the case of Staff and Michener Health Services in the case of Students. Written requests for exemptions to the requirements of this Policy due or grounds pursuant to the Human Rights Code should be submitted as soon as possible and by no later than September 24, 2021 for review to Michener’s People and Culture Department
Following the implementation of this Policy, Michener may review, revise and amend the requirements of this Policy in the face of evolving scientific evidence pertaining to the COVID-19 pandemic.
|September 16, 2021||People & Culture||document creation|