564 19 101 _ Flu and TB Tests Requirements.pdf

From: Lowry, Drew D.

To: Allison, Madeline Cc: Morehart, Zachary B.

Subject: 564 19 101 | CNWSF | Requirements for Contractors_Flu & TB Tests Date: Monday, August 10, 2026 10:51:41 AM Attachments: 00-88 Safety During Contruction.pdf

VHA Directive 1192.01.pdf Flu Appendix B 10-9050.pdf

Good Morning, Madeline, Please see below and attached received from Colleen this morning regarding annual flu vaccine and negative TB. Thank you.

Respectfully, Drew

From: Thomas, Colleen F. <Colleen.Thomas1@va.gov> Sent: Monday, August 10, 2026 10:40 AM To: Hardy, Cody R. <Cody.Hardy@va.gov>; Sims, Cody W. <Cody.Sims@va.gov>; Lowry, Drew D.

<Drew.Lowry@va.gov>; Staggs, Chase R. <Chase.Staggs@va.gov>; Osorio Gonzalez, Edwin A.

<Edwin.OsorioGonzalez@va.gov>; Morehart, Zachary B. <Zachary.Morehart@va.gov> Cc: Vinger, Jeffery A. (FAV) <Jeffery.Vinger@va.gov> Subject: Requirements for Contractors | Flu & TB Tests

Team, I have confirmed with our Infection Control team that all contractors are required to receive an annual flu vaccine and have a negative TB within 90 days prior to starting work. This applies to all VHA property and does not differentiate between interior or exterior work. This should be included in our project specifications, but I also recommend adding it under the “Badging” section of SOW’s. These forms should be documented during the submittal process and received prior to issuing contractor badges.

Flu Vaccine: The Flu Vaccine is required per VHA Directive 1192.01. There is a waiver available (Flu Appendix B) where a mask is required to be worn in lieu of receiving the vaccine.

TB: VA Specification 00‑88 – Safety and Health During Construction Activities, which states that all contract employees assigned to a worksite must have a negative TB test within 90 days prior to beginning work. This applies to all VHA property and does not differentiate between interior or exterior work, so the screening is required for both.

mailto:Drew.Lowry@va.gov mailto:Madeline.Allison@va.gov mailto:Zachary.Morehart@va.gov

Veterans Health Care System of the Ozarks (VHSO)

VHSO Memorandum Number 15-00-88

May 22, 2015

Safety and Health During Construction Activities

1. Purpose: To establish policy and procedures to ensure that construction projects will be planned, coordinated and regularly inspected to ensure compliance with applicable fire, infection control, environmental, security, safety, and occupational health regulations and policies.

2. Policy

a. It is the Policy of the VHSO to operate under a comprehensive construction safety program that seeks to reduce the potential for injury and illness to Veterans Affairs (VA) patients, employees, and visitors that might result from unsafe construction activities, to increase the level of construction safety expertise of VA employees, to decrease the potential for serious Occupational Safety and Health Administration (OSHA) violations, to provide a guideline for addressing safety-related construction issues, and to reduce the potential for property and liability exposures due to construction-related activities.

b. Construction activities shall be defined to include delegated minor or non-recurring maintenance projects performed by contractors or purchase and hire personnel, as well as facility-level projects performed by contractors, purchase and hire personnel or facility engineering personnel. Construction shall also include non-delegated projects including majors, and Veterans Health Care System of the Ozarks (VHSO) shall coordinate those construction impacts with the project’s Resident Engineer through VHSO’s single point of contact. This definition also applies to enhanced use and lease projects related to structures for which VHSO maintains management responsibility or authority.

3. Responsibility

a. Medical Center Director

(1) Establishing and monitoring an effective facility Construction Safety Program.

(2) Establishing a Multi-Disciplinary Team (Construction Safety Committee) with representatives from the following program areas:

(a) Infection Control

(b) Patient Safety

(c) Occupational Safety and Health

VHSO MCM 15-00-88

(d) VA Police

(e) Engineering (Facilities Management)

(f) Engineering (Projects Management)

(g) Green Environmental Management System (GEMS)

(h) Emergency Program Coordinator

(i) Local Union Safety Representatives (from affected bargaining units)

(j) Contracting

(k) Employee Occupational Health

(3) Designating a Construction Safety Officer(s) (CSO) that has the necessary training, experience, and authority to carry out their responsibilities with respect to safety and health during construction activities to oversee construction safety.

(4) Ensuring that Competent Persons (CP)s who have the necessary training, experience, and authority to carry out their responsibilities with respect to safety and health during construction activities are designated for the project. Title 29 Code of Federal regulations (CFR) 1926.32(f) states “competent person” means one who is capable of identifying existing and predictable hazards in the surroundings and working conditions which are unsanitary, hazardous or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.” Qualified VA staff must be appointed to serve as CP for construction work performed by VA employees. The name and qualifications of the CP must be identified in writing and noted in the minutes of the facility Safety Committee (or equivalent body) responsible for the safety management functions as defined under the Joint Commission (TJC) Environment of Care Standards.

(5) Ensuring that the Construction Safety Committee actively engages all areas of construction safety and fulfills all of its responsibilities.

(6) Developing and implementing a written facility policy addressing the responsibilities of the Construction Safety Committee.

(7) Ensuring that VA staff receives training as follows:

(a) Contracting Officer (CO) completes the OSHA 30 hour of Construction Safety Training and at least 10 hours of construction safety training every 2 years.

(b) Appointed CPs, Contracting Officer’s Representatives (COR)s, Construction Safety Officers, facility Safety Staff, and GEMS coordinator complete OSHA’s 30-hour Construction Safety Training initially, and subsequently complete at least 10 hours of Construction Safety Training at least every 2 years.

(c) Chief Engineers/Facilities Management, Resident Engineer(s) (RE), supervisors, and foremen who oversee construction work complete OSHA’s 30-hour Construction Safety Training initially, and subsequently complete at least 10 hours of Construction Safety Training at least every 2 years.

(d) Multi Disciplinary Team members for Patient Safety, Infection Control, VA Police, Emergency Management, Local Union representative, and Employee Health complete at a minimum the OSHA 10 hour Construction Safety Course or VA equivalent and receive a minimum of 10 hours construction training every 2 years

(8) Ensuring that construction contracts awarded after July 31, 2005, specify that on-site general and sub-contractor’s construction workers have completed at least 10 hours of Construction Safety Training, the 30-hour OSHA Construction Safety Training course, or other relevant competency training, as determined by the Construction Safety Committee with input from the Multi-Disciplinary Team. The determination for training is based on the project hazards and complexity, state and federal regulations and VA requirements.

b. Associate Director

(1) Completing responsibilities delegated from the Medical Center Director, as appropriate, for oversight of these policies.

c. Chief, Engineering Service

(1) Working through safety and health staff, CORs, maintenance staff, contractors, and the Construction Safety Committee to plan, coordinate, and monitor the Construction Safety Program for all projects at the facility.

(2) Working with contractor and Veterans Health Administration (VHA) facility staff to coordinate and monitor an effective Construction Safety Program for projects under their direction.

(3) Supporting the periodic inspections of construction sites.

(4) Acting as the Safety Officer in accordance with the Department of Veterans Affairs Acquisition Regulations (VAAR) 836.236-87 and ensuring contractors comply with VA safety and health policies and procedures, and contract requirements. This also applies to RE(s).

(5) Serving on the facility Construction Safety Committee to ensure contracts meet the committee’s requirements.

(6) Supporting the Construction Safety Officer, Facility Safety Manager, Contracting Officer, and engineering staff in implementing the Construction Safety Program.

(7) Supporting the CP, Safety Officer, Infection Control Practitioner, CO, and staff in implementation of the Construction Safety Program.

(8) Working with contracting staff to ensure competent staff is assigned as CORs to oversee work.

d. Supervisor of Operations and Maintenance

(1) Participating in periodic inspections of in-house construction sites to ensure compliance with safety elements of the construction contract and performance of the program.

(2) Ensuring that in-house work forces have necessary training and competency for tasks being performed.

e. Chief of Biomedical Engineering

(1) Ensuring that all construction accomplished in support of major equipment installations (as a part of the equipment purchase) are in compliance with the site Construction Safety Program policy and procedures.

f. Contracting Officer (CO) and Contracting Officer’s Representative (COR).

(1) Ensuring that all solicitations and contracts include the Federal Acquisition Regulation (FAR) clause found in Federal Acquisition Regulation (FAR) 52.236-13, Accident Prevention, and Veterans Affairs Acquisition Regulation (VAAR) clause found in VAAR 836.236-87.

(2) Designating, in writing, the CSO to serve as the Safety Officer for VHA contracts; and the RE to act as the Safety Officer for the Office of Construction & Facilities Management (CFM) contracts (applies to CO).

(3) Adding paragraph (f) found in Federal Acquisition Regulations (FAR) 52.236- 13 to the basic clause if the contract will involve work of a long duration or hazardous nature, or performance on a government facility that, on the advice of CSO or COR, involves hazardous materials or operations that might endanger the safety of the public or government personnel or property.

(4) Ensuring that all solicitations and contracts specify that on-site general and sub-contractor’s construction workers have completed at least 10 hours of Construction Safety training or the OSHA 30-hour Construction Safety training, and other relevant competency training, as determined by the CSO with input from the Multi-Disciplinary Team. The determination for other relevant competency training is based on the project hazards and complexity, Federal, and State regulations and VA requirements.

(5) Ensuring that all projects require contractor certification verifying completion of required training.

(6) Ensuring submittals for contract construction or renovation work to include the names, qualifications, and training dates for the contractor CP designated to administer the site-specific safety program, as well as the CP for other activities as required by OSHA regulation (such as scaffolds, cranes, excavations, etc.).

(7) Evaluating and considering past safety records of prospective contractors in awarding contracts. At a minimum, ensuring that all solicitations and contracts specify that contractors must not have more than three serious, or one repeat, or one willful OSHA violation(s) in the past 3 years or any significant environmental penalties.

Additionally, ensuring that all solicitations and contracts specify that contractors must have an Experience Modification Rate (EMR) of equal to or less than 1.0 (EMR of 1.0 indicates that a contractor had an average insurance claim’s rate for worker injuries)

(8) Serving on the facility Construction Safety Committee to ensure contracts meet the Committee’s requirements.

(9) Supporting the CSO, Facility Safety Manager, RE, and appropriate staff in implementing the construction safety program and enforcement of the contracts.

(10) Ensuring and maintaining record that, if contracted, construction worker(s) have been determined to be at risk for transmission of tuberculosis (TB) based upon the TB preconstruction risk assessment. The contractor must provide written certification that all contract employees assigned to the work site have had a pre-placement tuberculin screening within 90 days prior to assignment to the worksite and been found to be with negative screening reactions. This can be the Centers for Disease Control and Prevention (CDC) two-step skin testing or a Food and Drug Administration (FDA)-approved blood test. Employees manifesting positive screening reactions to the tuberculin must be examined, according to current CDC guidelines, prior to working on VHA property. Subsequently, if the employee is found without evidence of active (infectious) pulmonary TB, a statement documenting examination by a physician must be on file with the employer (construction contractor), noting that the employee with a positive tuberculin screening test is without evidence of active (infectious) pulmonary TB. If the employee is found with evidence of active (infectious) pulmonary TB, the employee would require treatment with a subsequent statement as outlined in subparagraph 4q (11)(c) before being allowed to return to work on VHA property.

(11) CORs are trained and designated as facility Construction Safety Officer(s)

(CSO).

g. Construction Safety Officer (CSO)

(1) Submitting project reviews of all construction projects.

(2) Providing oversight of contract construction safety.

(3) Being knowledgeable in the general inspection of typical work sites during construction and renovation performed by contract staff, and in the review of contractor safety program submittals. Note: CSO(s) do not take the place of the contractor’s CP nor act on their behalf. The CSO(s) determines if the contractor is meeting VA standards and contractual requirements for safety and OSHA compliance. When these standards and contract requirements are not being met, the VA Contracting Officer’s Representative (COR), CO, and CSC must take immediate action to prevent injury, exposure, non-compliance, and/or property damage.

(4) Ensuring that the specific safety requirements for construction operations are implemented during facility projects.

(5) Serving as a member of the Multi-Disciplinary Team.

(6) Conducting periodic inspections of VHA construction sites to ensure compliance with safety elements of the established program(s); at minimum, weekly inspections are required.

(7) Monitoring and inspecting construction and renovation work sites periodically to assure compliance with these policies.

(8) Maintaining competence in the general inspection of work sites during construction, renovation, and maintenance, falls under the purview of this policy.

(9) Approving corrective actions.

(10) Stopping unsafe work or activities that are non-compliant with the contract or OSHA and notifying the CO immediately.

(11) Maintaining communication with the contractor CP on questions of safety.

h. Facility Safety Program Manager

(1) Ensuring that VHA policy for the Construction Safety Program is implemented within the medical center.

(2) Chairing the Construction Safety Committee or assigning a designee to serve as the chair.

(3) Ensuring that necessary and relevant Interim Life Safety Measure (ILSM)s are established and implemented. Conducts required additional training for compliance with identified ILSMs.

(4) Rendering technical advice and assistance as required in connection with life safety and fire protection issues during construction, project design, and development.

(5) Overseeing compliance with OSHA and other relevant construction safety regulations.

(6) Confirming that VHSO staff receives training required by this memorandum.

(7) Ensuring that the Construction Safety Program includes appropriate periodic construction site hazard surveillance.

i. Infection Prevention Program Manager

(1) Advising and/or providing recommendations on exposure mitigation and the prevention of facility associated infections in patients, staff, and visitors.

(2) Coordinating with the manager of each construction project (in-house and contract) to conduct an Infection Control Risk Assessment (ICRA) during the planning and/or design stage of the work. ICRAs must be documented in writing and focus on eliminating, or minimizing, the risk of infection during construction and renovation activities.

(3) Monitoring infection prevention protocols during construction activities as indicated in ICRA for that project.

j. Green Environment Management System (GEMS) Coordinator

(1) Providing guidance on EPA regulations and environmental issues, as those regulations and issues directly and immediately relate to the safety during the design stage.

(2) Monitoring contractor compliance with contract specifications on Environmental Protection Agency (EPA) regulations, as those regulations directly and immediately relate to the construction project, including environmental compliance, pollution prevention, waste management, and permitting.

k. Emergency Program Coordinator

(1) Providing guidance on OSHA regulations as they apply to emergency planning, response, and operations in construction (i.e. 29 CFR 1926.35 and 29 CFR 1926.65).

(2) Monitoring contractor performance to contracted specifications on OSHA Regulations as they apply to emergency planning, response, and operations related to construction operations.

l. The Construction Safety Committee (Multi-Disciplinary Team)

(1) Determining the scope and depth of safety, infection control, emergency management, and security interventions appropriate for all construction work. The team may develop threshold criteria for each level of intervention. For instance, after review, some projects may require only CSO surveillance to ensure employee safety and OSHA compliance, while other projects will require all disciplines to be involved.

(2) Conducting preconstruction risk assessments for air quality requirements, infection control, utility requirements, noise, vibration, and other hazards that affect care, treatment, and services. Using the current American Institute of Architects (AIA) Guidelines, staff must conduct and document in writing preconstruction risk assessments during the design or planning stage of the work (prior to bidding, award, and starting work). Preconstruction risk assessments must focus on eliminating, or minimizing the above mentioned risks during construction and renovation activities. The complexity of the preconstruction risk assessment report is determined by the complexity of the threats posed by the construction project. Assigned VHA staff and CFM REs must confirm compliance during the construction phase of the work.

(3) Conducting a preconstruction risk assessment for the transmission of Mycobacterium Tuberculosis (TB) to the contracted construction workers based upon the construction site location, patient population, hospital layout, and the Centers for Disease and Prevention (CDC) defined risk as outlined in the “CDC Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in Health-Care Setting, 2005.”

(4) Ensuring ILSMs are assessed and implemented on all construction work in accordance with TJC Standards. ILSMs are required when Life Safety Code deficiencies or construction activities pose significant hazards as determined by the assessment. Each medical facility must have a local policy addressing ILSM as required by TJC.

(5) Participating in all phases of construction work from planning through completion. This includes review and approval of construction plans, contract specifications, and contract submittals related to construction safety and health and any other documents that may assist in the implementation of an effective Construction Safety Program. The Multi-Disciplinary Team must be involved early in the process and continue oversight on a regular basis to avoid costly and disruptive delays.

(6) Ensuring that the Construction Safety Program includes periodic construction site hazard surveillance activities with appropriate membership, scope, and frequency for each project as determined by the Construction Safety Officer and the preconstruction risk assessment. At a minimum, weekly surveillance activities are required. In some cases, daily inspections may be warranted. Hazard surveillance activities must be documented (date, time, members of the inspection team, deficiencies, type of corrective action, and time and date of correction). Correction of hazards must be tracked to completion.

(7) Ensuring all contractors entering VHA properties comply with the security management program. As a minimum, contractors must notify and obtain permission from the VA Police, be identified by project and employer, and be restricted from unauthorized access.

(8) Ensuring that all contractor employees have adequate documentation that they have no active tuberculosis.

(9) Evaluating the effectiveness of the Construction Safety Program in an annual report to the facility Safety Committee and/or Environment of Care Committee, or equivalent committee.

(10) Requiring the contractor CP to implement and maintain an effective Safety Program that identifies and controls hazards that may cause injury or illness to VA patients, staff, visitors, and contractor employees.

(11) Meeting at least monthly.

(12) Ensuring that documentation of the team’s inspections is provided to the Network Safety and Health Staff as requested.

m. VA Police

(1) Ensuring that all contractors entering VHSO property comply with the Security Management Program. At a minimum, contractors must notify and obtain permission of the VHSO Police, be identified by project and employer, and be restricted from unauthorized access.

(2) Conducting periodic surveillance of site security and the integrity of barriers for trenches and other hazards.

4. Intervention and Enforcement: All of the individuals with defined actions in this directive will intervene, whenever conditions, as a result of construction activities, immediately threaten life or health or threaten to damage equipment or buildings.

Intervention and enforcement of this Directive and the associated regulatory requirements are as follows:

a. Staff. All staff will identify hazardous conditions in need of intervention and further develop a culture of safety. CPs and all facility management will take prompt corrective measures to include immediate abatement of hazards, stopping of work, hazard awareness training, administrative controls, etc.

b. Contractors. The Construction Safety Officer or CO shall notify the contractor orally, with written confirmation, and request immediate initiation of corrective action of hazards identified. After receiving the notice, the Contractor shall immediately take corrective action. If the Contractor fails or refuses to promptly take corrective action, the CO may issue an order stopping all or part of the work until satisfactory corrective action has been taken (Federal Acquisition Regulations (FAR) 52.236-13). Upon a repeat offense of the same or substantially similar hazard, the Construction Safety Officer or CO should inform OSHA or other authorities (i.e., federal, state, or local officials) of the instances where the contractor has been notified to take immediate action to correct serious or imminent dangers (FAR 36.513). The Construction Safety Officer, with assistance from the Multi-Disciplinary Team, is responsible for making the Contractor and CO formally aware of hazards in need of correction. The CO is responsible for enforcement of the contract.

5. References: VHA Directive for Safety and Health during Construction.

6. Rescissions: Medical Center Memorandum (MCM) 12-00-88 dated May 22, 2012.

7. Rescission: MCM will expire on May 22, 2018.

5/18/2015

X Mark A. Worley, MD, PhD

Medical Center Director

Signed by: MARK A. WORLEY 144125

5/13/2015

X W. Keith Neeley, FACHE

Associate Medical Center Director

Signed by: Neeley, William K. (FAV)

5/17/2015

X John Krueger MD, MPH

Chief of Staff

Signed by: people

5/13/2015

X Amy S. Lesniewski, RN MS

Associate Director for Patient Care Services

Signed by: AMY S. LESNIEWSKI 162378

Distribution: Via Intranet

T-1

Department of Veterans Affairs Veterans Health Administration Washington, DC 20420

VHA DIRECTIVE 1192.01

Transmittal Sheet

August 10, 2020

SEASONAL INFLUENZA VACCINATION PROGRAM FOR VHA HEALTH CARE

PERSONNEL

1. REASON FOR ISSUE: To establish policy and provide guidance for mandatory seasonal influenza vaccination among health care personnel (HCP) in the Veterans Health Administration (VHA).

2. SUMMARY OF CONTENT: This VHA directive requires all HCP covered by the policy to receive annual seasonal influenza vaccination.

3. RELATED ISSUES: VHA Directive 1013(3) Prevention and Control of Seasonal Influenza with Vaccines. Wherever this directive conflicts, it supersedes any prior local or national VHA policy related to influenza vaccination and influenza prevention in HCP.

4. RESPONSIBLE OFFICE: The Office of Occupational Safety and Health (10NA5B) is responsible for the contents of this VHA directive. Questions may be referred to the Clinical Occupational Health Program at VHAEOHProgram@va.gov.

5. RESCISSIONS: VHA Directive 1192, dated September 26, 2017, is rescinded.

6. RECERTIFICATION: This VHA directive is scheduled for recertification on or before the last working day of August 31, 2025. This VHA directive will continue to serve as national VHA policy until it is recertified or rescinded.

BY DIRECTION OF THE OFFICE OF

THE UNDER SECRETARY FOR HEALTH:

/s/ Renee Oshinski Assistant Under Secretary for Health for Operations

NOTE: All references herein to VA and VHA documents incorporate by reference subsequent VA and VHA documents on the same or similar subject matter.

DISTRIBUTION: Emailed to the VHA Publications Distribution List on August 10, 2020.

mailto:VHAEOHProgram@va.gov

August 10, 2020 VHA DIRECTIVE 1192.01 i

CONTENTS

1. PURPOSE

2. BACKGROUND

3. DEFINITIONS

4. POLICY

5. RESPONSIBILITIES

6. REFERENCES

APPENDIX A

PROCEDURES FOR IMPLEMENTING THE SEASONAL INFLUENZA VACCINATION

PROGRAM AT VHA FACILITIES. ....................................................................................A-1

APPENDIX B

HEALTH CARE PERSONNEL INFLUENZA VACCINATION FORM .............................B-1

1. PURPOSE

This Veterans Health Administration (VHA) directive establishes policy and provides guidance for the prevention of seasonal influenza in VHA facilities through the vaccination of health care personnel (HCP). AUTHORITY: Title 38 United States Code (U.S.C.) §§ 7301(b), 7318(b).

2. BACKGROUND

a. The Centers for Disease Control and Prevention (CDC), the Advisory Committee on Immunization Practices (ACIP) and the Healthcare Infection Control Practices Advisory Committee (HICPAC) recommends that all United States health care workers are vaccinated annually against influenza (also known as “flu”).

b. Influenza viruses are transmitted mainly by droplets made when people with flu cough, sneeze or talk, in a manner similar to other respiratory pathogens that cause severe acute viral respiratory syndromes. These droplets can land in the mouths or noses of people who are approximately six feet away from an infected person or possibly be inhaled into the lungs. Influenza viruses have contributed to several prior pandemics.

c. CDC reported 81.1% of HCP in the U.S. received an influenza vaccination during the 2018–19 season, similar to reported coverage in the previous four seasons. The percentage of VHA HCP immunized against influenza has been lower than the national percentage, nearing 65-75%, despite efforts to increase vaccination compliance over the past five years.

d. Influenza is particularly severe in certain populations, especially the elderly, frail and immunosuppressed, and its transmission is an underrecognized yet substantial safety concern, accounting for millions of influenza-related medical illnesses and visits, hundreds of thousands of hospitalizations and several thousand deaths annually across the United States. CDC estimated the national burden of flu related illnesses from October 1, 2019 to April 4, 2020 as 39,000,000 – 56,000,000 flu illnesses, 18,000,000 – 26,000,000 flu medical visits, 410,000 – 740,000 flu hospitalizations and 24,000 – 62,000 flu deaths. Within VHA, there were 4,610 influenza-coded hospitalizations, 617 ICU stays and 107 deaths in the 2019 – 2020 flu season. The overall VHA flu hospitalization rate for the 2019 – 2020 season was 67.8 per 100,000 Veterans in care.

e. Society and professional norms set the expectation that HCP “do no harm” to the patients they treat and serve. Accordingly, every reasonable step should be taken to prevent transmission of influenza in VHA facilities. This prevention effort is multipronged. It includes annual vaccination of patients and HCP, proper hand hygiene, respiratory hygiene, cough etiquette and HCP self-exclusion from work during illness.

f. Annual vaccination is widely recognized as the best method for preventing disease and death related to influenza. Vaccination of both patients and HCP is the cornerstone of efforts to prevent healthcare-associated influenza transmission. Vaccination of HCP reduces the risk that HCP will become infected with influenza, thereby reducing the risk of transmission to susceptible patients and co-workers and contributing to maintaining a healthy workforce to care for patients.

g. In 2010 the Department of Health and Human Services (HHS) established a goal of 90 percent for HCP influenza vaccination in its Healthy People 2020 and National Action Plan to Prevent Healthcare-Associated Infections. Despite a mandatory seasonal influenza participation program in VHA, VHA has failed to meet the vaccination goal of 90 percent of HCP.

h. The Centers for Medicare and Medicaid Services (CMS) has also endorsed a goal of 90 percent for HCP influenza vaccination compliance, and now expects all participating facilities to report HCP influenza vaccination rates to the National Healthcare Safety Network (NHSN) as required by the Hospital Inpatient Quality Reporting Program and Hospital Outpatient Quality Reporting Program.

i. Policies mandating influenza vaccination of HCP are supported or endorsed by many leading professional and health care consumer organizations, including the American Hospital Association, the American College of Physicians, the American Academy of Pediatrics, the American Nurses Association, the Society for Healthcare Epidemiology of America, the Infectious Disease Society of America, the Pediatric Infectious Disease Society, the Association of Professionals in Infection Control and Epidemiology and the National Patient Safety Foundation.

j. Members of the Council of Teaching Hospitals, including many leading academic medical institutions in the United States, have implemented policies for HCP influenza vaccination as have the Department of Defense, the Indian Health Service and the National Institutes of Health Clinical Center.

k. According to the Immunization Action Coalition, there are currently 1139 organizations and 291 Long-Term Care / Assisted Living organizations on the Influenza Vaccination Mandates Honor Roll, which recognizes stellar influenza vaccination mandates nationwide.

3. DEFINITIONS

a. Face Mask. For the purposes of this directive a face mask is a loose-fitting disposable mask, provided by VHA, that covers the nose and mouth. Face masks should be worn as outlined in local and national policies. Fitted N95 respirators or other respirators are not required by this policy, but they should be used when appropriate to the task (e.g., when caring for a patient on airborne infection isolation precautions); if N95 or higher respirators are used, they also serve the purpose of being considered a face mask for this directive.

b. Health Care Personnel (HCP). HCP are individuals who, during the influenza season, work in VHA locations or who come into contact with VA patients or other HCP as part of their duties. VHA locations include, but are not limited to, VA hospitals and associated clinics, community living centers (CLCs), community-based outpatient clinics (CBOCs), domiciliary units, Vet centers and VA-leased medical facilities. HCP include all VA licensed and unlicensed, clinical and administrative, remote and onsite, paid and without compensation, full- and part-time employees, intermittent employees, fee basis employees, VA contractors, researchers, volunteers and health professions trainees (HPTs) who are expected to perform any or all of their work at these facilities. HPTs may be paid or unpaid and include residents, interns, fellows and students. HCP also includes VHA personnel providing home-based care to Veterans and drivers and other personnel whose duties put them in contact with patients outside VA medical facilities.

NOTE: This definition does not include visitors to the medical facility, including individuals who enter to conduct occasional or sporadic services, surveyors, inspectors, political representatives, or media personnel. Also excluded are non-VA personnel providing home services through contracts with VA and private facilities providing care under contract with VA. However, the exclusion of contracted non-VA personnel and facilities from this policy does not preclude VA from requiring influenza vaccination of these personnel in their respective contracts; in fact, this practice should be strongly supported and encouraged.

c. Influenza Season. For the purposes of this directive, the influenza season is generally considered to span the four-month period from December 1 through March 31; however, it can vary from one season or geographic location to another. Individual VHA facilities may expand (but not reduce) this time period based on local influenza activity and other epidemiological circumstances.

d. Influenza Vaccine. Influenza vaccine is any Food and Drug Administration approved, commercially available product recommended by the CDC for the prevention of influenza in a particular season.

4. POLICY

It is VHA policy that medical facilities will achieve a mandatory seasonal influenza vaccination program by requiring all HCP to receive annual seasonal influenza vaccination or obtain an exemption for medical or religious reasons. Compliance with this directive is a condition of employment. HCP in violation of this directive may face disciplinary action up to and including removal from federal service.

5. RESPONSIBILITIES

a. Under Secretary for Health. The Under Secretary for Health is responsible for the overall authority of this directive.

b. Assistant Under Secretary for Health for Support Services. The Assistant Under Secretary for Health for Support Services is responsible for:

(1) Providing oversight to the VHA Office of Occupational Safety and Health (10NA5B) and ensuring that it maintains the resources necessary to implement this directive.

(2) Collaborating with the Assistant Under Secretary for Health for Operations and the Assistant Under Secretary for Health for Quality and Patient Safety to support monitoring, reporting and evaluation of the impact of this directive as guided by the VHA Office of Occupational Safety and Health.

c. Assistant Under Secretary for Health for Operations. The Assistant Under Secretary for Health for Operations is responsible for:

(1) Facilitating consistent compliance across VISNs with the seasonal influenza vaccination program as prescribed in this directive.

(2) Distributing communications pertaining to implementation, interpretation and evaluation of this directive as developed by the VHA Office of Occupational Safety and Health.

(3) Collaborating with the Assistant Under Secretary for Health for Support Services and the Assistant Under Secretary for Health for Quality and Patient Safety to support monitoring, reporting and evaluation of the impact of this directive as guided by the VHA Office of Occupational Safety and Health.

d. Assistant Under Secretary for Health for Quality and Patient Safety. The Assistant Under Secretary for Health for Quality and Patient Safety is responsible for:

(1) Collaborating with the Assistant Under Secretary for Health for Support Services and the Assistant Under Secretary for Health for Operations to support monitoring, reporting and evaluation of the impact of this directive as guided by the VHA Office of Occupational Safety and Health.

e. Director, VHA Office of Occupational Safety and Health. The Director, VHA Office of Occupational Safety and Health is responsible for:

(1) Ensuring the appointment of Program Office personnel to implement the requirements of this directive.

(2) Ensuring that adequate resources are provided to implement the requirements of this directive.

f. Medical Advisor, VHA Office of Occupational Safety and Health. The Medical Advisor, VHA Office of Occupational Safety and Health is responsible for:

(1) Developing and administering a standardized program to measure HCP vaccination status and rates and compliance with this directive across all VA medical facilities.

(2) Working closely with the National Seasonal Influenza Program, within the VHA National Center for Health Promotion and Disease Prevention, to provide further guidance on policies, procedures, education and training resources.

(3) Working closely with the Office of Reporting, Analytics, Performance, Improvement and Deployment (RAPID) to provide performance measures; oversight and compliance findings; and HCP influenza vaccination data requests.

g. Clinical Occupational Health Program Manager for Policy Oversight, VHA Office of Occupational Safety and Health. The Clinical Occupational Health Program Manager for Policy Oversight is responsible for:

(1) Developing and consistently interpreting policies, procedures and guidance for implementation and operation of the seasonal influenza vaccination program for VHA

HCP.

(2) Serving as a liaison between those listed in Section 5 of this directive to relay seasonal vaccination program compliance data as relevant to each individual stakeholder.

h. Clinical Occupational Health Program Manager for Operations, VHA Office of Occupational Safety and Health. The Clinical Occupational Health Program Manager for Operations is responsible for:

(1) Overseeing the implementation and operation of the seasonal influenza vaccination program for VHA HCP, including communicating with facility and leadership stakeholders about implementation of the program.

(2) Promoting VHA use of existing or improved systems, tools and technologies to manage the documentation and reporting of HCP seasonal influenza vaccination.

i. Veterans Integrated Service Network Director. Each Veterans Integrated Service Network (VISN) Director is responsible for:

(1) Ensuring that necessary resources are available to implement and oversee the seasonal influenza vaccination program for VHA HCP in the VISN.

(2) Ensuring that all facilities within the VISN participate in oversight activities and measurements prescribed by the VHA Office of Occupational Safety and Health for the purposes of evaluating the seasonal influenza vaccination program for VHA HCP.

(3) Reporting to the Director, VHA Office of Occupational Safety and Health, or designee, all metrics prescribed by the VHA Office of Occupational Safety and Health for the purposes of evaluating the seasonal influenza vaccination program for VHA

HCP.

j. VA Medical Facility Director. Each VA medical facility Director is responsible for:

(1) Ensuring that all aspects of this directive are implemented at the medical facility.

(2) Ensuring HCP have access to available training or education pertaining to proper use of face masks and other mitigation strategies that reduce the spread of flu. This includes clarification on how to access face masks, when to wear a mask, type of mask to wear, when to replace a mask, and proper disposal of masks, according to local and national policies.

(3) Designating personnel to respond to questions and address matters of local implementation related to HCP participation and guidance from the VHA Office of Occupational Safety and Health in the form of a VHA facility ad hoc work group.

(4) Ensuring VHA facility Employee Occupational Health personnel have the appropriate resources for implementation and operation of the seasonal influenza vaccination program for VHA HCP.

(5) Ensuring all HCP are notified of the requirement to participate in the seasonal influenza vaccination program, as described in Appendix A.

(6) Reporting to the VISN Director all metrics prescribed by the VHA Office of Occupational Safety and Health for the purposes of evaluating the seasonal influenza vaccination program.

(7) Ensuring HCP have access to information on: the existence, role, and procedures related to the VHA facility ad-hoc workgroup of subject matter experts; the current CDC Vaccination Information Sheet (VIS); the package inserts for flu vaccines used by the VHA facility that year; available training or education pertaining to flu, flu vaccine and flu prevention, including proper use of face masks and other mitigation strategies that reduce the spread of flu.

(8) Addressing non-compliant HCP, in conjunction with the HCP’s supervisor and Chief Human Resources Officer, as necessary.

k. VISN Chief Human Resources Officer. The Chief of Human Resources at each VISN is responsible for:

(1) Notifying all applicants/prospective employees of the requirement to participate in the seasonal influenza vaccination program. (See Appendix B.)

(2) Aggregating and reporting all administrative actions resulting from violations of this directive to each VISN Director as prescribed by the VHA Office of Occupational Safety and Health for the purposes of evaluating the seasonal influenza vaccination program.

l. Chief, Voluntary Service. The Chief, Voluntary Service or other designated official at each VHA facility is responsible for:

(1) Notifying all current and prospective volunteers about the seasonal influenza vaccination program’s vaccination requirement and providing them with information about how to comply with this directive.

(2) Providing and updating the roster of volunteers for VHA facility Employee Occupational Health.

(3) Counseling those volunteers who are not compliant with the requirements set by this directive and implementing actions determined by the VHA facility Director or designee for volunteers found to be in violation of this directive.

m. Designated Education Officer (DEO) or Designee. The DEO or his/her designee at each VA medical facility is responsible for all facility HPTs and:

(1) Ensuring through the Trainee Qualifications and Credentials Verification Letter (TQCVL) process that each HPT is aware of the VHA seasonal influenza vaccination program requirements.

(2) Receiving and maintaining trainee compliance certification via the TQCVL for all HPTs including paid and without compensation.

(3) Communicating with the academic affiliate and appropriate individuals at the VA medical facility about the necessity of HPT compliance with VHA Directive 1192.01 on Seasonal Influenza Vaccination Program for VHA Health Care Personnel.

(4) Monitoring trainee compliance and documentation is the responsibility of the Designated Education Officer.

n. VHA Facility Employee Occupational Health Staff. Employee Occupational Health staff at each facility is responsible for:

(1) Ensuring appropriate entry and maintenance of all documentation involving vaccination or exemption by HCP in accordance with VA Handbook 5019, Employee Occupational Health Service, August 3, 2017 or successor policy.

(2) Formulating and communicating the local process for secure receipt of documentation involving vaccination or exemption by HCP.

(3) Documenting and monitoring influenza vaccination compliance of all HCP and identifying to the VHA facility executive leadership those individuals who have not signed and submitted the Health Care Personnel Influenza Vaccination Form, VA Form 10-9050 (Appendix B) by November 30.

NOTE: VHA Facility Employee Occupational Health staff may not identify individuals according to their vaccination status or otherwise indicate whether an individual has been vaccinated unless that individual has provided a qualifying authorization permitting the disclosure on VA Form 10-5345 Request for and Authorization to Release Health Information. Questions should be referred to the local Privacy Office.

(4) Aggregating, analyzing and reporting to the VHA facility Director all metrics prescribed by the VHA Office of Occupational Safety and Health for the purposes of evaluating the VHA HCP seasonal influenza vaccination program.

o. Health Care Personnel (HCP). HCP are required to comply with this directive by:

(1) Receiving the annual seasonal influenza immunization or obtaining an exemption for medical or religious reasons.

(2) Submitting the Health Care Personnel Influenza Vaccination Form, VA Form 10- 9050 (Appendix B) by November 30 of each year to Employee Occupational Health.

(3) Wearing a face mask as described in Appendix A of this directive when an exemption to the influenza vaccination has been granted.

Compliance with this directive is a condition of employment. HCP in violation of this directive may face disciplinary action up to and including removal from federal service.

p. VA Contracting Officers. Contracting Officers shall ensure the flu vaccination requirements outlined in this directive are expected in all HCP contracts. VA contracting officers responsible for on-site HCP contract will inform the contractors about this directive and its requirements.

6. REFERENCES

a. Centers for Disease Control and Prevention. Influenza Vaccination Coverage Among Health Care Personnel — United States, 2018–19 Influenza Season.

https://www.cdc.gov/flu/fluvaxview/hcp-coverage_1819estimates.htm. Accessed June 23, 2020.

b. Centers for Disease Control and Prevention. Preliminary In-Season 2019-2020 Burden Estimates. https://www.cdc.gov/flu/about/burden/preliminary-in-season-estimates.htm. Accessed June 23, 2020.

c. Centers for Disease Control and Prevention. Immunization of health-care personnel: recommendations of the Advisory Committee on Immunization Practices (ACIP). MMWR Recomm Rep. 2011;60(RR-7):1-45.

d. Centers for Disease Control. National Healthcare Safety Network HCP Influenza Vaccination Summary Reporting Requirements: General.

https://www.cdc.gov/nhsn/faqs/vaccination/faq-influenza-vaccination-summary-reporting.html. Accessed June 24, 2020.

e. Centers for Disease Control. Prevention and Control of Seasonal Influenza with Vaccines: Recommendations of the Advisory Committee on Immunization Practices – United States, 2019-20 Influenza Season. MMWR; August 23, 2019; 68(3): 1-21.

https://www.cdc.gov/vaccines/hcp/acip-recs/vacc-specific/flu.html. Accessed July 14, 2020.

https://www.cdc.gov/flu/fluvaxview/hcp-coverage_1819estimates.htm https://www.cdc.gov/flu/about/burden/preliminary-in-season-estimates.htm https://www.cdc.gov/flu/about/burden/preliminary-in-season-estimates.htm https://www.cdc.gov/nhsn/faqs/vaccination/faq-influenza-vaccination-summary-reporting.html https://www.cdc.gov/nhsn/faqs/vaccination/faq-influenza-vaccination-summary-reporting.html https://www.cdc.gov/vaccines/hcp/acip-recs/vacc-specific/flu.html

f. Centers for Disease Control and Prevention. How Flu Spreads.

https://www.cdc.gov/flu/about/disease/spread.htm, Accessed June 25, 2020.

g. Department of Defense. DoD Instruction 6205.02. July 23, 2019. DoD Immunization Program.

https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/620502p.pdf?ver=20 19-07-23-085404-617. Accessed June 23, 2020Department of Defense. Influenza Infection and Influenza Vaccines Information Paper. May 18, 2020.

http://www.health.mil/Military-Health-Topics/Health-Readiness/Immunization- Healthcare/Vaccine-Preventable-Diseases/Influenza-Seasonal?page=1#pagingAnchor.

Accessed June 23, 2020.

h. Immunization Action Coalition. Influenza Vaccination Honor Roll. Honorees with Influenza Vaccination Mandates. https://www.immunize.org/honor-roll/influenza-mandates/honorees.asp. Accessed June 23, 2020.

i. Immunization Action Coalition. Influenza Vaccination Honor Roll. Mandatory Influenza Vaccination for Healthcare Personnel Position Statements.

https://www.immunize.org/honor-roll/influenza-mandates. Accessed June 23, 2020.

j. Indian Health Service. Seasonal Influenza Immunizations for Civilian Healthcare Personnel. https://www.ihs.gov/ihm/circulars/2016/mandatory-seasonal-influenza-immunizations-for-civilian-health-care-personnel/#8. Accessed June 23, 2020.

k. Geoghegan S, Kitt E, Offit P. Influenza Vaccination in Health Care Workers.

Infectious Disease Special Edition. Fall 2019. 75-79 https://www.idse.net/download/FluVaccine_IDSE0919_WM.pdf Accessed June 19,

l. Frederick J. Brown A, Cummings D. et al. Predicting Healthcare Personnel in Outpatient Settings; The influence of Mandatory vs Nonmandatory Influenza Vaccination Policies on Workplace Absenteeism During Multiple Respiratory Virus Seasons. Infection Control and Hospital Epidemiology 2018; 39, 452-461.

https://www.cambridge.org/core/journals/infection-control-and-hospital-epidemiology/article/protecting-healthcare-personnel-in-outpatient-settings-the-influence-of-mandatory-versus-nonmandatory-influenza-vaccination-policies-on-workplace-absenteeism-during-multiple-respiratory-virus-seasons/18BDBBB8BAE3C60051342A6D75689304/core-reader# Accessed June 22,

m. Greene, M.T., Fowler, K.E., Ratz, D. et al. Changes in Influenza Vaccine Requirements for Health Care Personnel in US Hospitals. JAMA Network Open .

:(2)1;2018 https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2682876.

Accessed June 22, 2020.

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