Immunization Information for Healthcare Workers

Healthcare workers are at increased risk for getting sick and passing illness to patients. It may be more difficult for these patients to recover from illnesses. It is critical that healthcare workers get immunized against vaccine preventable diseases so that they, and the people they care for, are less likely to become ill. Vaccines are effective at preventing disease among healthcare workers and the patients around them. (more)

Immunization and testing requirements for healthcare workers

A series of immunization and testing requirements are in place in Rhode Island for healthcare workers (Immunization, Testing, and Health Screening for Health Care Workers Regulations).

A checklist for facilities and answers to many frequently asked questions regarding these regulations are available. The answers to many frequently asked questions about how these requirements affect EMTs are also available.

What We Are Doing

On December 5, 2012, the Director of the Rhode Island Department of Health declared influenza to be widespread in Rhode Island. All healthcare workers should be vaccinated against seasonal influenza as soon as possible. The purpose of the masking requirement - as the regulations state in section 5.11 - is to “ensure patient safety and to reduce the chance of healthcare workers spreading the influenza virus.” New regulations enacted in October 2012 require healthcare workers who are not vaccinated against seasonal influenza to wear a surgical face mask during direct patient contact if the Director of Health declares influenza to be widespread. As of December 5, 2012, the entire State of Rhode Island has been declared by the Director to be in a period in which influenza is widespread. When the Director declares this period to be over, the masking requirement will no longer be in effect, unless a new declaration is made at a later time.

What You Should Do

Vaccination against influenza is the most important method to prevent spread of infection. For healthcare personnel who have not yet been vaccinated, the use of surgical masks may help limit exposure to respiratory infection or its spread to others.

In the event that masking precautions for healthcare workers are required to prevent spread of disease or control outbreaks (for example, during a Declaration of Widespread Influenza), facility administrators and supervisors are encouraged to review the following in preparation for implementation:

Wear a Mask If You Are Not Vaccinated

• Unvaccinated healthcare workers must wear a mask when they are involved in direct patient contact during a declaration of a widespread influenza period.
• Unvaccinated healthcare workers do not have to wear a mask for an entire shift unless they have direct patient contact the entire shift. Infectious disease experts recommend using a new mask at least every four hours or sooner if the mask becomes too moist or soiled.  The mask may be removed if no patients are near, or approaching near, the healthcare worker.
• Infectious disease experts also recommend that those wearing a mask should replace it if damaged; avoid touching the inside or outside of a mask that could be dirty; and remove a worn mask, discard into general trash, and then perform hand hygiene before touching any items.
• The regulations do not require healthcare workers to wear a mask for seven days after vaccination. However, it is still recommended practice to do so.
• The regulations clearly state in section 5.5 that “No healthcare worker shall be required to explain his or her refusal to obtain an annual seasonal influenza vaccination, nor shall any healthcare facility inquire into the basis of such refusal.” Nothing in the regulation allows or mentions that healthcare workers should or must be identified to the public. The requirement is to wear a mask -- not a badge or a colored dot, or anything but a surgical face mask. No explanation must be provided to employers or patients.
• A surgical face mask must be worn by unvaccinated healthcare workers even if they have filed a medical exemption certificate or a refusal form with their employer. Filing a medical exemption certificate or refusal form is the only vehicle that may exempt healthcare workers from obtaining an influenza vaccination; but the medical exemption certificate or refusal form does not exempt such workers from wearing a surgical face mask during direct patient contact during a declaration of widespread influenza.
• When unvaccinated EMTs employed by a private ambulance service enter a healthcare facility, they must wear a mask during direct patient contact (during a widespread influenza period, see sections 1.6, 5.3 and 5.4), but nothing in the regulation indicates the wearing of the mask must be continuous or outside of a facility. Regulations do not permit a facility to stop an unmasked and unvaccinated EMT from entering it.
• Unvaccinated licensed healthcare workers who violate the masking requirement during the widespread influenza declaration period are subject to a $100 fine per violation and disciplinary action. The $100 fine is not payable to the facility. It will be levied only after a complaint is filed with HEALTH, investigated, referred to the appropriate licensing board, and after an opportunity for a hearing. If the fine is levied, it will be payable to the General Treasurer.
• Unvaccinated doctors with privileges at healthcare facilities must wear a mask at the facilities during direct patient contact during the widespread influenza period, even though they need not wear a mask at their private offices.

Sign the Proper Forms if Refusing Vaccine

• Unvaccinated healthcare workers who do not sign a refusal or medical exemption form, and/or refuse to wear a mask, may be reported to the HEALTH complaint line at 222-5200. Facilities that wish to take further action may consider consulting legal counsel and human resources staff, but must understand that the HEALTH regulations do not call for further discipline other than what HEALTH and/or the licensing board issues.
• Each year December 15 is the deadline for healthcare workers reporting to the facility that employs them that they have received the influenza vaccination, have a medical exemption, or are refusing to get vaccinated and have signed a declination form. At a later date, healthcare facilities are required to report the numbers (not names) of healthcare workers who have received the influenza vaccination, who have a medical exemption, and who refuse.
• Medical exemption certificates should not be sent to the Department of Health. The healthcare facility must keep the medical exemption certificates in the healthcare worker's file.

Report to the Department of Health

• Regulations section 3.5.4 (d) states that each healthcare facility is responsible for reporting to the Rhode Island Department of Health:
• The number (but not names) of healthcare workers who are eligible for influenza vaccination;
• The number (but not names) of healthcare workers who received influenza vaccination; and
• The number (but not names) of healthcare workers who decline annual influenza vaccination for medical or personal reasons, reported by each of the two (2) categories.
• Reporting shall occur according to procedures and format required by the Department of Health. Specifics about those procedures and format shall be sent to healthcare facilities in the coming weeks.

Definitions

• If you are an unvaccinated healthcare worker in one of the following types of healthcare facilities, this new regulation about surgical face masks applies to you: hospital, nursing home, home nursing agency, rehab center, kidney treatment center, HMO, hospice, freestanding emergency facility, and some ambulatory surgical centers.
• The term “healthcare worker” includes any person who is temporarily or permanently employed by (or at) – or who is a volunteer in – or who has an employment contract with – a healthcare facility, as defined in the previous paragraph. This includes physicians (while working at such a facility, but not in their private offices), physician assistants, nurses, CNAs, therapists (psychotherapist, occupational, physical, speech), technicians, clinicians, behavior analysts, social workers, EMTs (while at a facility), dental personnel, pharmacists, lab personnel, students, trainees, those with privileges at a facility, and staff who have patient contact such as clerical, dietary, housekeeping, laundry, security, maintenance, administrative, and billing.
• The regulations define “direct patient contact” as all routinely anticipated face-to-face contact with patients, such as when: speaking with a patient in person; entering a patient’s room; transporting a patient throughout facility; handing out medications; performing a procedure on a patient; in a cafeteria line; participating in group patient activities; serving food to patients. The definition does not include times when a healthcare worker is in areas such as breakrooms or personal work stations that no patients approach.
• The regulations apply only to healthcare workers in a healthcare facility in Rhode Island (see regulation sections 1.6 and 2.1).  Private practices and assisted living centers are not healthcare facilities.