D.43 COVID-19 Guidance on Vaccine Administration 02.pdf
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- 36C25923R0008
About this file
This document is COVID-19 Guidance on Vaccine Administration from the Department of Veterans Affairs. It provides guidance on accommodating VA providers' conscience-based exemptions (CBEs) to administering COVID-19 vaccines, while ensuring Veterans receive timely care. The guidance states that CBEs should be accommodated unless doing so unfairly affects patient health, creates unwarranted burdens, or leads to illegal practices. Facilities should proactively identify vaccinator objections and make reasonable accommodations, such as scheduling objectors for clinics administering vaccines they do not object to. However, in rare cases where alternate vaccinators are unavailable, the facility may need to decline the CBE accommodation to provide care to Veterans. The guidance also notes that Veteran choice on COVID-19 vaccines may be limited by factors like supply and distribution, and must be balanced against maximizing benefit for all Veterans. Contacts are provided for questions on conscience-based exemptions and vaccine-related inquiries.
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Text version
Department of Veterans Affairs
Date: March 3, 2021
From: Assistant Under Secretary for Health for Operations (15) Assistant Under Secretary for Health for Clinical Services (11)
Subj: COVID-19: Guidance on Vaccine Administration
To: Veterans Integrated Service Network (VISN) Directors (10N1–23)
VISN Chief Medical Officers VISN Chief Nurse Officers
1. Department of Veterans Affairs (VA) is committed to protecting providers’ moral integrity, while ensuring that patients receive care to which they are legally entitled in an appropriate and timely manner. The goal of COVID-19 vaccination is to offer protection to as many Veterans as possible, with any vaccine that can be made available to them most quickly.
2. If a VA provider requests a conscience-based exemption (CBE) to providing a vaccine, consistent with VA Guidance the exemption should be accommodated unless honoring it results in outcomes that unfairly affect the patient’s health, place unwarranted burdens on the patient or organization, or would lead to an illegal practice.
o Facilities should provide information in advance to all potential vaccinators about vaccines they will be administering so that objections can be identified and proactively addressed. This ensures that reasonable accommodations can be made while not adversely affecting Veterans. This information could be provided in the national Talent Management System (TMS) training on
Janssen COVID-19 vaccine or any vaccine that may raise concerns for vaccinators.
o Reasonable accommodations should be made to address the vaccinators’ concerns, including but not limited to:
▪ Scheduling vaccinators for clinics where they will only administer vaccines for which they have no objection (e.g. the Moderna or Pfizer- BioNTech COVID-19 vaccines clinic instead of the Janssen COVID-19 vaccine clinic)
▪ Requesting that any vaccinators who volunteer for duty are comfortable administering any vaccine with which they are supplied.
o In the rare instance that alternate vaccinators are not available, it may be ethically justifiable to decline the accommodation of a conscience-based exemption so that VA is able to provide care to Veterans.
o Cases in which a staff member declines to perform the identified duty after
Memorandum
D.43 COVID-19: GUIDANCE ON VACCINE ADMINISTRATION
36C25923R0008 https://vaww.va.gov/vhapublications/ViewPublication.asp?pub_ID=7892 their request for accommodation of a CBE is denied, should be managed D.43 COVID-19: GUIDANCE ON VACCINE ADMINISTRATION 36C25923R0008
Subj: COVID-19: Guidance on Vaccine Administration according to Human Resources policies for employees who are not performing their duties.
3. In the case that a Veteran objects to one vaccine, the facility should attempt to coordinate vaccination if a reasonable opportunity is available. However, Veteran choice related to COVID-19 vaccines may be limited by a variety of factors (e.g.
supply, storage, and distribution requirements) and must be balanced against maximizing benefit for all Veterans.
4. Should you have questions regarding conscience-based exemptions and ethical considerations, please contact Dr. Toby Schonfeld, Executive Director, National
Center for Ethics in Health Care by sending an email to Toby.Schonfeld@va.gov .
For questions related to vaccines, please submit to the COVID-19 Resource Room or send an email to VHACOVIDRR@va.gov.
Renee Oshinski Kameron Leigh Matthews, JD, MD, FAAFP
Attachment
D.43 COVID-19: GUIDANCE ON VACCINE ADMINISTRATION
36C25923R0008 mailto:Toby.Schonfeld@va.gov mailto:VHACOVIDRR@va.gov
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